SecProbe.io

CORRESP
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  June 24, 2005

Ms. Cicely Luckley

Securities and
Exchange Commission

Mail Stop 4561

Washington, DC
20549

Re:          Advanstar, Inc.

Dear Ms.
Luckley:

We are writing this letter to respond to the comment letter of the
Staff dated June 16, 2005 with respect to Advanstar, Inc.’s (the “Company”)
Form 10-K for the year ended December 31, 2004. For your convenience, we have
reproduced the Staff’s comment preceding the Company’s response.

Advise us how your audit report complies with Auditing Standard No. 1
of the PCAOB, References in Audit Reports to the Standards of the Public
Company Accounting Oversight Board.

The audit of the Company’s consolidated
financial statements was conducted in accordance with the standards of the
Public Company Accounting Oversight Board (United States). The omission of the
reference to the Public Company Accounting Oversight Board was
unintentional.  We will amend our 2004
Form 10-K to include an audit report that complies with Auditing Standard No. 1
of the PCAOB, References in Audit Reports to Standards of the Public Company
Accounting Oversight Board.

* * * * *

In addition, as requested by the Staff, the Company hereby acknowledges
that:

•      the Company is responsible for the adequacy and accuracy of
the disclosure in its filings;

•      staff comments or changes to disclosure in response to staff
comments do not foreclose the Commission from taking any action with respect to
the filings; 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.

* * * * *

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If you have
any questions or comments about the foregoing, please do not hesitate to
contact me at (218)723-9222.  You may
also contact the Company’s outside counsel, Michael P. Kaplan, of Davis Polk
& Wardwell. at (212) 450-4111.

  Sincerely,

  /s/ David W.
  Montgomery

  David W.
  Montgomery

cc:           Ralph Hamann

Michael P. Kaplan

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