SecProbe.io

Mail Stop 4561
May 5, 2006

Mr. Kenneth J. Kay
Chief Financial Officer
CB Richard Ellis Group, Inc.
100 N. Sepulveda Blvd., Suite 1050
El Segundo, CA 90245

 Re: CB Richard Ellis Group, Inc.
  Form 10-K for the Fiscal Year Ended December 31, 2005
  File No. 1-32205

Dear Mr. Kay:

We have reviewed your filing and have the following comment.  We have limited
our review of your filing to the issue we have addressed in our comment.  In our
comment, we ask you to provide us with information so we may better understand your disclosures.  After reviewing this information, we may raise additional comments.

 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 on any other aspect of our review.  Feel free to call us at the telephone numbers listed at the end of this letter.

Item 7 Management’s Discussion and Analysis of Financial Condition and Results of
Operations

Segment Operations, page 42

1. Reference is made to your reconciliation of segment operating income to EBITDA.  Please tell us how you determined segment operating income is a reconcilable measure under Item 10(e) of Regulation S-K.  In addition, please refer to the June 13, 2003 FAQ Regarding the Use of Non-GAAP Financial Measures.

Please respond to this comment within 10 business days or tell us when you will
provide us with a response.  Please file your response on Edgar.

We urge all persons who are responsible for the accuracy and adequacy of the
disclosure in the filings to be certain that the filings include all information required

Mr. Kenneth J. Kay
CB Richard Ellis Group, Inc.
May 5, 2006 Page 2

under the Securities Exchange Act of 1934 and that they have provided all information investors require for an informed investment 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 comment, 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 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.

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

You may contact Thomas Flinn, Staff Accountant, at (202) 551-3469 or the
undersigned at (202) 551-3498 if you have questions.

 Sincerely,

Linda van Doorn
Senior Assistant Chief Accountant