SecProbe.io

June 30, 2009  Mail Stop 3010
By U.S. Mail and facsimile to (949) 809-4357

Mr. Robert E. Sulentic, Chief Financial Officer
CB Richard Ellis Group, Inc. 1150 Santa Monica Boulevard, Suite 1600 Los Angeles, CA     90025
RE: CB Richard Ellis Group, Inc.
            File No.  001-32205
 Form 10-K for the year ended December 31, 2008

Dear Mr. Sulentic:
We have reviewed your response letter submitted on May 8, 2009 and have the
following comments.
In our comments, we ask you to provide us with information so we may better
understand your disclosure.  Please be as detail ed as necessary in your explanation.  After
reviewing this information, we may raise additional comments.

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 filing.  We look forward to  working with you in these respects.
We welcome any questions you may have about  our comment or on any other aspect of
our review.  Feel free to call us at the tele phone numbers listed at th e end of th is letter.

Selected Financial Data, page 32; Management’s Discussion and Analysis of Financial
Condition and Results of Operations, pages 45, 51 and 53

1. We have read and considered your re sponse to comment one. We note that you
believe that your impairment charge is similar to amortization expense, however
your impairment charge relates to intangi bles not subject to  amortization. Also,
your description of EBITDA differs from the description of EBITDA in Article
10(e) of Regulation S-K which does not include adjustments for impairment
charges. As previously requested, explai n to us how you considered the guidance
in Question 14 of the Frequently Aske d Questions Regarding the Use of Non-
GAAP Financial Measures in determining whether it is appropriate to characterize this measure as “EBITDA.” Also, expl ain how you considered disclosing why

CB Richard Ellis Group, Inc.
Page 2 of 2
you believe it is useful to investors to di sregard the impairment charge eliminated
from the measure.

Financial Statements

Note 15 – Commitments and Contingencies, page 116

2. We have read and considered your respons e to comment five. Please tell us what
your accounting policy is under SFAS 140, FIN 45 or SFAS 5 for recording a provision for the loss you would incur upon the requirement to perform under
your loss sharing arrangements with Fannie Mae.  Also, please clarify whether you have been required to perform under this obligation and if so, tell us the
dollar amount of the loss.

As appropriate, please respond to these co mments within 10 business days or tell
us when you will provide us with a response.  Please submit your response letter on EDGAR. Please understand that we may have additional comments after reviewing your
responses to our comments.
  You may contact Jorge L. Bonilla at ( 202) 551-3414 or me at (202) 551-3413 if
you have any questions,                                                                                      Sincerely,
                                                                                  Cicely LaMothe
                                                                                  Branch Chief