SecProbe.io

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								June 2, 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.
Supplemental response letter dated May 24, 2005 regarding the
Annual
Report on Form 10-K (fiscal year ended December 28, 2004)
		File No. 33-89818

Dear Mr. Beckert:

	We have reviewed your supplemental response letter to us
dated
May 24, 2005 in response to our letter of comment dated May 5,
2005
and have the following comments.  Where indicated, we think you
should revise your documents 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.  In some of our comments, we may
ask you to provide us with supplemental information so we may
better
understand your disclosure.  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 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 look forward to working with you in these respects.  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.

John A. Beckert
ClubCorp, Inc.
June 2, 2005
Page 2

Form 10-K for the Fiscal Year Ended December 28, 2004
Financial Statements

Note 11. Segment Reporting, page F-21

1. We understand, from response one of your letter dated May 24,
2005, that operating income is not included in the periodic
financial
information provided to the chief operating decision maker.  In
support of your response, please provide us with a copy of the
periodic reporting package.  We may have further comments upon
review
of this information.

2. The term EBITDA is commonly understood to refer to earnings
before
interest, taxes, depreciation and amortization.  If your measure
of
segment profitability differs from this description, please label
it
"adjusted EBITDA" or in some similar manner.

3. In addition to the changes you propose to make to the "Segment
Reporting" note in the financial statement footnotes, please also
revise to delete any presentation of EBITDA on a consolidated
basis.

4. In addition to the changes you propose to make to your MD&A
discussion, please expand your detailed discussions of operations
to
more thoroughly address changes in operating income on a
consolidated
basis.  As indicated above, any EBITDA discussions and
presentations
should pertain only to your individual segments.

Closing

      You may contact Ms. Beverly A. Singleton, Staff Accountant,
at
(202) 551-3328, or Ms. Margery Reich, Senior Staff Accountant, at
(202) 551-3347 if you have questions regarding comments on the
financial statements and related matters.  Please contact me at
(202)
551-3211 with any other questions.

      Sincerely,

								David R. Humphrey
								Accounting Branch Chief

cc:	Mr. Garrett A. DeVries, Esq.
	Haynesboone
	Facsimile (214) 200 - 0428

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