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Letter to the SEC

December 14, 2005

Rufus Decker

Branch Chief

United States

Securities and Exchange Commission

Washington, D.C. 20549-7010

               Re:

    Form 10-K for the Fiscal Year ended January 2, 2005

Forms 10-Q for the Fiscal Quarters ended April 3, 2005 and July 3,

2005 and October 2, 2005

File No. 1-14260

Dear Mr. Decker:

     The GEO Group, Inc. (“GEO”), hereby responds to the comments of the staff (the “Staff”) as set
forth in the letter dated November 23, 2005 (the “Letter”), with respect to GEO’s Form 10-K for the
year ended January 2, 2005, and Form 10-Qs for the periods ended April 3, 2005, July 3, 2005 and
October 2, 2005.

     Please note that for your convenience of reference, we have recited below each comment
included in the Staff’s Letter and provided GEO’s response to such comment.

Form 10-Q for the period ended October 2, 2005

Item 4 – Controls and Procedures, page 33

You stated that disclosure controls and procedures were effective in timely alerting you to
material information that is required to be included in your periodic SEC filings.

Please note that you have provided an incomplete definition of disclosure controls and
procedures per Rules 13a-15(e) and 15d-15(e) of the Exchange Act. Please revise in future
filings your definition to clarify, if true, that your disclosure controls and procedures
were effective to “to ensure that information required to be disclosed in [your] filings
under the Securities Exchange Act of 1934 is recorded, processed, summarized and reported
within the time periods specified in the Securities and Exchange Commission rules and
forms.” Please also clarify in future filings your definition to also clarify, if true,
that your disclosure controls and procedures were effective to ensure that information
required to be disclosed by you in the reports that you file or submit under the Exchange
Act is accumulated and communicated to your management, including your principal executive
and principal financial officers, or persons performing similar functions, as appropriate

to allow timely decisions regarding required disclosure. Please show us what your revised
disclosure would look like.

GEO intends to revise Part II, Item 9A of its future Form 10-K filings and Part I, Item 4 of
its future 10-Q filings to include language similar to the following:

“CONTROLS AND PROCEDURES

(a) Disclosure Controls and Procedures.

     Our management, with the participation of our Chief Executive Officer and our
Chief Financial Officer, has evaluated the effectiveness of our disclosure controls
and procedures (as such term is defined in Rules 13a-15(e) and 15d-15(e) under the
Securities Exchange Act of 1934, as amended (the “Exchange Act”)) as of the end of
the period covered by this report. On the basis of this review, our management,
including our Chief Executive Officer and our Chief Financial Officer, has concluded
that as of the end of the period covered by this report, our disclosure controls and
procedures were effective to give reasonable assurance that the information required
to be disclosed in our reports filed with the Securities and Exchange Commission
(the “SEC”) under the Exchange Act is recorded, processed, summarized and reported
within the time periods specified in the rules and forms of the SEC, and to ensure
that the information required to be disclosed in the reports filed or submitted
under the Exchange Act is accumulated and communicated to our management, including
our Chief Executive Officer and our Chief Financial Officer, in a manner that allows
timely decisions regarding required disclosure.

     It should be noted that the effectiveness of our system of disclosure controls
and procedures is subject to certain limitations inherent in any system of
disclosure controls and procedures, including the exercise of judgment in designing,
implementing and evaluating the controls and procedures, the assumptions used in
identifying the likelihood of future events, and the inability to eliminate
misconduct completely. Accordingly, there can be no assurance that our disclosure
controls and procedures will detect all errors or fraud. As a result, by its
nature, our system of disclosure controls and procedures can provide only reasonable
assurance regarding management’s control objectives.”

     Thank you for your attention to this matter. Please do not hesitate to contact the
undersigned at (561) 999-7401 with any questions or comments you may have on the foregoing.

    Very truly yours,

    /s/ John G. O'Rourke

    John G. O'Rourke

    The GEO Group, Inc.
Senior Vice President and Chief Financial Officer

    cc:

    John J. Bulfin

David N. T. Watson

Brian R. Evans

Jose Gordo (via overnight mail)