SecProbe.io

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Mail Stop 3-5

									April 20, 2005

Via Facsimile (212) 318-3400 and U.S. Mail
Richard A. Palmer
Fulbright & Jaworski L.L.P.
666 Fifth Avenue
New York, NY 10103-3198

Re:	Pulitzer, Inc.
	PREM 14A filed on March 29, 2005
	File No. 1-14541

Dear Mr. Palmer:

      We have reviewed the above filing and have the following
comments.  Where indicated, we think you should revise your
document
in response to these comments.  If you disagree, we will consider
your explanation as to why our comment is 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 this information, we may or may not
raise additional comments.

      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 and welcome any questions you may have
about our comments or on any other aspect of our review.  Feel
free
to call us at the telephone numbers listed at the end of this
letter.

General
1. Please supplementally send us a copy of the board book and any
other materials prepared by Goldman Sachs to assist the board in
evaluating the transaction.  Also, provide us with a copy of the
engagement letter.
2. Please disclose why the board chose to hire two financial
advisors
and what role Huntleigh Securities Corporation played.  If
Huntleigh
provided a report or opinion, you should describe this report or
opinion in accordance with Item 1015 of Regulation M-A.

Interests of Directors and Executive Officers in the Merger, page
5
3. Please quantify the aggregate amount of money that will be paid
to
directors and executive officers in the merger.  Also, clarify
here,
if true, that there may be continuing employment opportunities for
executive officers in the new enterprise after the merger.

Questions and Answers about the Merger, page 6
4. You might consider asking and answering why you are bothering
to
have a vote since the outcome appears not in doubt.

The Merger, page 13
Background of the Merger, page 20
5. Name the consulting firm mentioned in the second sentence of
this
section.
6. Revise to name the "other advisors" retained to assist you with
your exploration of strategic alternatives in the carryover
paragraph
at the top of page 16.
7. If the two leaks described, respectively, in the last paragraph
on
page 16 and the third paragraph on page 19, affected the process,
please describe.
8. It appears that the final discussions were to resolve "certain
compensation and benefit issues" after the price per share was
set.
Please disclose what the issues were and how they were resolved,
quantifying where practicable.

Reasons for the Merger, page 22
9. Please revise into two lists, one of reasons in favor of the
merger; the other, of reasons against.

Opinion of our Financial Advisor, page 29
10. Disclose why you use both large and mid-cap companies in your
analysis and disclose which you consider Pulitzer.
11. With regard to your disclosure of the various valuation
analyses
that Goldman used in providing its opinion, please revise to
indicate
what each analysis indicates to investors. We suggest that you
provide a prose discussion of what the tables mean and how they
impact or relate to the determination that the transaction is
fair.
12. In the DCF and LBO analyses, explain why particular perpetuity
growth rates and exit multiples were chosen to calculate terminal
values, as well as why particular discount rates and target rates
of
return were used.  Also, it would be helpful to show the cash
flows
that were used.
13. Revise your DCF discussion to include tabular disclosure
similar
to that used in your descriptions of other analyses.
14. It is unclear from the narrative why your LBO analysis
supports a
finding of fairness.  Please revise to clarify.

Financial Projections, page 37
15. We note your statement that "None of Pulitzer, our board of
directors or Goldman Sachs assumes any responsibility for the
reasonableness, completeness, accuracy or reliability for the
projections."  While we do not object to the use of qualifying
language with respect to the projections, we believe that
disclaimers
of responsibility that in any way state or imply that investors
are
not entitled to rely upon statements made in the proxy statement
are
unacceptable.  Please revise to delete.
16. Also revise to clarify, if true, that the projections
represented
management`s good faith, best efforts at projections at the time
they
were prepared.

Material United States Federal Income Tax Consequences, page 45
17. Please delete the initial sentence of the bolded paragraph on
page 46.

Litigation Challenging the Merger, page 46
18. Supplementally provide us copies of the complaints in the
shareholder litigation discussed in this section.

Appraisal Rights, page 66
19. Please revise your disclosure to clarify whether shareholders
can
perfect their appraisal rights by either not returning the proxy
card, by abstaining or by signing and returning the proxy card but
not giving voting instructions.  If state law is unclear, state
what
position will be taken in regard to these matters.  See
Instruction 1
to Item 3.
Representations and Warranties, page 48
20. In an appropriate place in the proxy statement, please address
the effect of the shareholder litigation on the representation and
warranty as to the absence of any outstanding litigation or
judgment
against you.

Closing Comments

	We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings reviewed by the staff to
be
certain that they have provided all information investors 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 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 filings;
* staff comments or changes to disclosure in response to staff
comments in the filings reviewed by the staff 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.

*  *  *

      Please amend the Schedule 14A in response to these comments.
Marked copies of the amendments greatly facilitate our review.
Please furnish a cover letter with your amendment that keys your
responses to our comments and provides any requested supplemental
information.  Please file the response letter as correspondence on
EDGAR.  Detailed cover letters greatly facilitate our review.

      You may contact Mat Bazley at (202) 551-3382 with any other
questions or you may reach me at (202) 551-3750.

Sincerely,

								Max A. Webb
								Assistant Director
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Pulitzer, Inc.
April 22, 2005
Page 1

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