SecProbe.io

August 21, 2007  Mail Stop 3561

By U.S. Mail and facsimile to (310) 405-8950

Brett White President and Chief Executive Officer CB Richard Ellis Group Inc. 100 North Sepulveda Blvd., Suite 1050 El Segundo, CA 90245

Re: CB Richard Ellis Group Inc.
 Definitive 14A
Filed April 24, 2007
 File No. 1-32205

Dear Mr. White:
 We have limited our review of your definitive proxy statement to your executive
compensation and other related disclosure a nd have the following comments.  Our review
of your filing is part of the Division’s  focused review of executive compensation
disclosure.
Please understand that the purpose of our re view process is to assist you in your
compliance with the applicable disclosure  requirements and to  enhance the overall
disclosure in your filings.  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 me at the telephone number listed at the e nd of this letter.
  In some comments we have asked you to provide us with additional information so we may better understand your disclosure.  Pl ease do so within the time frame set forth
below.  You should comply with the remain ing comments in all future filings, as
applicable.  Please confirm in writing that you will do so and also explain to us how you
intend to comply.  Please unders tand that after ou r review of all of your responses, we
may raise additional comments.     If you disagree with any of these commen ts, we will consider your explanation as
to why our comment is inapplicable or a revisi on is unnecessary.  Please be as detailed as
necessary in your explanation.

Brett White
CB Richard Ellis Group Inc  August 21, 2007 Page 2  Compensation Committee Interlocks a nd Insider Participation, page 15

1. Provide the disclosure requi red by Item 407(e)(4)(i)(C) of Regulation S-K, rather
than simply cross-referencing to the Re lated Party Transactio ns Section.  This
disclosure is required to accompany the id entification of the directors in this
section.

Director Independence, page 17
2. Provide the disclosure required by Item 407(a)(3) of Regulation S-K.  For each
director and nominee for dire ctor that is identified as  independent, describe, by
specific category or type, any transacti ons, relationships or arrangements not
disclosed pursuant to Item 404(a) that were considered by the board of directors
under the applicable independence definitions  in determining that the director is
independent.  The current disclosure simply  indicates that the named directors are
independent under the standards set forth, but does not address whether any of
these transactions, relationships or arra ngements were considered in making this
determination.

Compensation Discussion and Analysis, page 25
3. When discussing the compensation program  objectives, clarify the policies for
allocating between long-term and curre ntly paid out compensation and for
allocating between cash and non-cash comp ensation.  See Item 402(b)(2)(i) and
(ii) of Regulation S-K.
4. You state on page 26 that your “pay pr actices are highly di fferentiated based on
individual performance, leadership a nd potential.”  Please disclose how the
specific forms of compensation are struct ured and implemented to reflect each
named executive officer’s individual perf ormance and/or individual contribution
to these items of the registrant’s pe rformance, describing the elements of
individual performance and/or contributi on that are taken into account.  See Item
402(b)(2)(vii) of Regulation S-K.
5. We refer you to Release 33-8732A, Sec tion II.B.1.  As noted therein, the
Compensation Discussion and Analysis shoul d be sufficiently precise to identify
material differences in compensation policies with respect to individual executive officers.  Please explain the reasons for the differences in the amounts of
compensation awarded to the named executive officers.  For example, Mr. White received the highest base salary of $650,000, which was approximately $150,000
above that of the next highest base sala ry paid, and approximately $2 million in
non-equity incentive plan compensation, which was over $1 million more than the next highest paid award under the plan.  We direct your attention to Item
402(b)(2)(vii) of Regulation S-K.

Brett White
CB Richard Ellis Group Inc  August 21, 2007 Page 3
6. Disclose in greater detail the role of the CEO in the compensation process.  See
Item 402(b)(2)(xv) of Regulation S-K.

Short-term or annual incentive bonuses, page 27

7. You have not provided quantitative disc losure of the terms of the necessary
targets to be achieved for your executiv e officers to earn their short-term or
annual incentive compensation.  Please disc lose the specific target EBITDA used
to determine incentive amounts or provide a supplemental analysis as to why such disclosure may be omitted pursuant to Inst ruction 4 to Item 402(b) of Regulation
S-K.  In addition, you state that 20% of this compensation is based upon strategic
measures, which “includes EBITDA margin  plus other qualitative measures.”
Please note that qualitative goals generally need to be presented to conform to the
requirements of Item 402(b)(2)(v) of Re gulation S-K.   Lastly, we note the
statement that your target financial pe rformance, in your opinion, “represents
aggressive goal setting.”  To the extent  that it is appropriate to omit specific
targets, please provide disclosure pursua nt to Instruction 4 to Item 402(b) of
Regulation S-K.  General statements rega rding the level of difficulty, or ease,
associated with achieving performance goals  either corporately or individually are
not sufficient.  In discussing how likely it will be for the company to achieve the
target levels or other fa ctors, provide as much detail as necessary without
providing information that poses a reasona ble risk of competitive harm.  Provide
similar disclosure or analysis relating to the financial and strategic measures
established for 2007, as referenced on page 31.

Long-term incentives, page 28

8. It is unclear how the company determin es the amount (or formula) for the long-
term incentive stock options and restri cted stock.  The disclosure currently
indicates that long-term incen tives are targeted at the ma rket median for your peer
group.  Please clarify and explain wh ether there are specific objective
performance-related factors that are us ed to determine the incentive awards.
These awards are being made pursuant to the 2004 Stock Incen tive Plan, which is
designed to qualify as “performance based compensation.”

Changes to our compensation program in 2007
9. You state that you replaced the compen sation consultant in December 2006.
Name the prior compensation consulta nt and discuss their role in the
compensation process for 2006.  See Item  407(e)(3)(iii) of Regulation S-K.

Brett White
CB Richard Ellis Group Inc  August 21, 2007 Page 4  Summary Compensation Table, page 32

10. Mr. Nugent was Executive Vice-President of your subsidiary CB Richard Ellis
Inc. as of your annual report for 2005.  It  appears that it may be appropriate to
include Mr. Nugent in the tabl e.  We direct your attenti on to Instruction 2 to Item
402(a)(3) of Regulation S-K regarding the inclusion of an executive officer of a
subsidiary.  In addition, if Mr. Nugent is no longer Executive Vice-President for
your subsidiary, he may fall within the re quirements of Item 402( a)(3)(iv).  Please
tell us what consideration you gave to this matter.

Non-Qualified Deferred Compensation, page 40
11. Clarify the type(s) of compensation perm itted to be deferred, and any limitations
(by percentage of compensation or otherwis e) on the extent to which deferral is
permitted.  See Item 402(i)(3 )(i) of Regulation S-K.
12. Disclose the material terms with resp ect to payouts, withdrawals and other
distributions, as required by Item 402(i)(3)( iii) of Regulation S-K.  For example,
state whether distribu tions are made in a lump sum payment or installments.
Also, clarify the “limited flexibility” to change distribution elections once made.
Lastly, disclose the material terms of the Trammell Crow Company DCP.

Related Party Transactions, page 47
13. Name the stockholders affiliated with Blum  Capital Partners that as a group own
14.2% of the outstanding Class A common stock.  See Item 404(a)(1) of
Regulation S-K.

 Please respond to our comments by September 21, 2007, or tell us by that time when you will provide us with a response.
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 all in formation required under
the Securities Exchange Act of 1934 and th at they have provided all information
investors require for an informed invest ment decision.  Since the company and its
management are in possession of all facts re lating to a company’s disclosure, they are
responsible for the accuracy and adequacy  of the disclosures they have made.
  When you respond 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 filing;

Brett White
CB Richard Ellis Group Inc  August 21, 2007 Page 5
• staff comments or changes to disclo sure in response to comments do not
foreclose the Commission from taking a ny action with respect to the filing;
and

• the company may not assert staff comme nts as a defense in any proceeding
initiated by the Commission or any pers on under the federal s ecurities laws of
the United States.

In addition, please be advise d that the Division of Enfo rcement has access to all
information you provide to the staff of the Di vision of Corporation Finance in connection
with our review of your filing or in response to comments.
 Please contact me at (202) 551-3357 with any questions.

Sincerely,

Pam Howell Special Counsel