SecProbe.io

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							May 5, 2005

By U.S. Mail and Facsimile [ (972) 888 - 7583 ]

Mr. John A. Beckert,
  Chief Executive Officer and President
CLUBCORP, INC.
3030 LBJ Freeway, Suite 600
Dallas, Texas  75234

	Re:	ClubCorp, Inc.
Annual Report on Form 10-K (fiscal year ended December 28, 2004)
		Filed: April 12, 2005
		File No. 33-89818

Dear Mr. Beckert:

	We have reviewed the above referenced filing based upon an
examination restricted solely to considerations of Selected
Financial
Data, Management`s Discussion and Analysis, and the Financial
Statements and have the following comments.  Where indicated, we
think you should revise your document in response to these
comments
in an amendment to the December 28, 2004 Annual Report on Form 10-
K.
Please confirm that such comments will be complied with.  If you
disagree, we will consider your explanation as to why our comments
are inapplicable or a revision is unnecessary.  Please be as
detailed
as necessary in your explanation.  After reviewing the
information,
we may or may not raise additional comments.

	Pursuant to Rule 101(a)(3) of Regulation S-T, your response,
should be submitted in electronic form, under the label "corresp",
and be provided within ten (10) business days from the date of
this
letter, and an amendment to the Form 10-K should be filed within
15
business days from the date of this letter.

	Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We welcome any questions you may have about our comments or any
other
aspect of our review.  Feel free to call us at the telephone
numbers
listed at the end of this letter.

May 5, 2005

John A. Beckert
ClubCorp, Inc.
Page 2

FORM 10-K (Fiscal Year Ended December 28, 2004)

Financial Statements

Note 11. Segment Reporting, page F-21

1. SFAS 131 requires disclosure of information about reportable
operating segments, including "a measure of segment profit or
loss."
The amount of segment profit or loss reported should be the
measure
reported to the chief operating decision maker for purposes of
making
decisions about allocating resources to the segment and assessing
its
performance.  If more than one segment profitability measure is
used,
paragraph 30 of the statement requires that the reported measure
should be that which management believes is determined in
accordance
with the measurement principles most consistent with those used in
measuring the corresponding amounts in the consolidated financial
statements.  You represent that you evaluate segment performance
and
allocate resources based upon each segment`s "EBITDA."  However,
you
actually report a figure representing segment operating income in
your footnote as well.  Further, the operating discussions
presented
in the business section of your filing (pages 4 - 6) clearly focus
on
segment operating income.  We note that these discussions cross-
reference directly to Note 11.  Your MD&A discussions focus on
segment operating income as well.  On the basis of the narrative
disclosures you have presented throughout your filing, we believe
that segment operating income is the measure of segment
profitability
that should be reported in Note 11.  Further, if "EBITDA" is not
the
measure of segment profitability for which disclosure is required
pursuant to SFAS 131, it constitutes a non-GAAP financial measure.
As such, its presentation in your financial statements and in MD&A
is
not appropriate.  Please see Questions 18 and 19 of the June 13,
2003
FAQ regarding the use of non-GAAP financial measures for guidance
and
revise or advise.  We may have additional comments upon review of
any
supplemental response.

Note 12. Benefit plans, page F-25

2. See the section of `Detail of Options Exercisable.`  As the
range
of the high and low exercise prices for options is wide, the
exercise
prices should be segregated into ranges that are meaningful for
assessing the number and timing of additional shares that may be
issued.  Please expand your disclosure accordingly.  See paragraph
48
of SFAS No. 123.

May 5, 2005

John A. Beckert
ClubCorp, Inc.
Page 3

Other

	We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing reviewed by the staff to
be
certain that they have provided all information investors require
for
an informed decision.  Since the company and its management are in
possession of all facts relating to a company`s disclosure, they
are
responsible for the accuracy and adequacy of the disclosures they
have made.

	In connection with responding to our comments, please
provide,
in writing, a statement from the company acknowledging that:

* the company is responsible for the adequacy and accuracy of the
disclosure in the filing;

* staff comments or changes to disclosure in response to staff
comments do not foreclose the Commission from taking any action
with
respect to the filing; and

* the company may not assert staff comments as a defense in any
proceeding initiated by the Commission or any person under the
federal securities laws of the United States.

			In addition, please be advised that the Division of
Enforcement has access to all information you provide to the staff
of
the Division of Corporation Finance in our review of your filing
or
in response to our comments on your filing.

Closing

      You may contact Ms. Beverly A. Singleton, Staff Accountant,
at
(202) 942-1912, or Ms. Margery Reich, Senior Staff Accountant, at
(202) 942-1839 if you have questions regarding comments on the
financial statements and related matters.  Please contact me at
(202)
942-1995 with any other questions.

      Sincerely,

							David R. Humphrey
							Accounting Branch Chief

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