SecProbe.io

September 3, 2014

Via E -mail
Karl McDonnell
Chief Executive Officer
Strayer Education, Inc.
2303 Dulles Station Boulevard
Herndon, VA 20171

Re: Strayer Education, Inc.
Form 10-K for Fiscal  Year Ended  December 31, 201 3
Filed February 26 , 201 4
Form 10 -Q for Fiscal Quarter Ended June 30, 2014
Filed August 1, 2014
  File No. 000-21039

Dear Mr. McDonnell :

 We have reviewed your filing s and have the following comments.  We have limited our
review to only your financial statements and related disclosures and do not intend to expand our
review to other portions of your documents.  Please comply with the following comments in
future filings.  Confirm in writing that you will  do so and explain to us how you intend to
comply.   In some of our comments, we may ask you to provide us with  information so we may
better understand your disclosure.

Please respond to this letter within ten business days by providing the requested
infor mation  or by advising us when you will provide the requested response.   If you do not
believe our comments apply to your facts and circumstances, please tell us why in your response.

After reviewing the information you provide in response to these  comme nts, we may
have  additional comments.

Form 10 -K for Fiscal Year Ended December 31, 201 3

Management’s Discussion and Analysis of Financial Condition and Results of Operations

Critical Accounting Policies, Revenue Recognition, page 39

1. Please tell us and disclose in future filings how you account for the credits earned from
your Graduation Fund.  If material, please quantify the amounts and where classified on
the Balance Sheet.  Please also comply in your Significant Accountin g Policies section of
your no tes to the financial statements.

Mr. Karl McDon nell
Strayer Education, Inc.
September 3, 2014
Page 2

 Form 10 -Q for Fiscal Quarter Ended June 30, 2014

Management’s Discussion and Analysis of Financial Condition and Results of Operations

Revenues, Income from Operations, and Net Income, p ages 16  and 18

2. Please disclose in  greater quantified detail the correlation between declining revenue,
average student enrollment, and the impact of your new pricing structure for
undergraduates.  Consider breaking out your explanation of variances between your
graduate and undergraduate programs.

We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing includes the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules require.   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 responding to our comments, please provide  a written statement f rom 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 wit h 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.

You may contact Robert Shapiro , Staff Accountant, at (202) 551 -3273 or Joseph M.
Kempf , Senior Staff Accountant,  at (202) 551 -3352  if you have questions regarding comments
on the financial statements and related matters.  Please contact me at (202) 551 -3810 with any
other questions.

Sincerely,

/s/ Robert S. Littlepage, for

Larry Spir gel
Assistant Director