SecProbe.io

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-7010

       DIVISION OF
CORPORATION FINANCE

        July 1, 2010
By U.S. Mail and facsimile to (310) 405-8950

Brett White Chief Executive Officer CB Richard Ellis Group, Inc. 11150 Santa Monica Boulevard, Suite 1600 Los Angeles, California

Re: CB Richard Ellis Group, Inc.
 Form 10-K for the year ended 12/31/2009
Filed on 3/01/2010 File No. 001-32205 Definitive Proxy on Schedule 14A filed on April, 19, 2010
                        Your response letter submitted on May 14, 2010
Dear Mr. White:

We have reviewed your filing and have the following comments.  In some of our
comments, we may ask you to provide us w ith information so we may better understand
your disclosure.
 Please respond to this letter within ten business days by amending your filing, by
providing the requested information, or by advising us when you will provide the requested response.  If you do not believe our comments apply to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
 After reviewing any amendment to your filing and the information you provide in
response to these comments, we may have additional comments.  Form 10-K for the year ended 12/31/2009

Consolidated Statements of Operations, page 75

1. We note your response to comment five  relating to your consideration of
Rule 3-09 of Regulation S-X.  Pl ease provide us your calculation of
average income showing the amount used for each year averaged and
explain how you considered your share of income or loss from your equity
investees in determining whether you  qualify for income averaging. Also,
explain how you considered the amo unts attributable to non-controlling

Brett White
CB Richard Ellis Group, Inc. July 1, 2010
Page 2

interest in your calcula tion.  Refer to notes 1 and 2 to Rule 1-02(w) of
Regulation S-X.

Definitive Proxy on Schedule 14A filed on April, 19, 2010
 Executive Compensation

 Compensation Discussion and Analysis

 Our 2009 Compensation Program, page 24

 Elements of our compensation program, page 26

2. We note your disclosure that you be nchmark your compensation against
your business services sector peers identified under th is subheading.
Please revise to identify each benchmark and include a discussion of where actual payments fall within targeted parameters for each element of
compensation.  To the extent actual compensation was outside a benchmark, include an explanation of the reasons for this. Please provide
sample disclosure in your response a nd confirm that you will provide such
disclosure in future filings.

3. While we note your disclosure of the actual percentage of the target goal
awarded to each of your executives for the strategic component of the
annual performance bonus, it is unclear how you determined the
percentages.  Please tell us how you determined the actual performance of
each executive relative to the strategic measures identified at the bottom of
page 28 and also describe how each ex ecutive’s performance resulted in
the percentages set forth for each executive.  Confirm that you will
provide similar disclosure in future filings. Refer to Item 402(b)(2)(v) of
Regulation S-K.

4. Please tell us briefly how the co mpensation committee determined the
targeted percentages for the strate gic measure component of the bonus
award for each executive.  Confir m that you will provide similar
disclosure in future filings. Refer to  Item 402(b)(2)(vii) of Regulation S-K.

 You may contact Jorge Bonilla, Senior St aff Accountant, at (202) 551-3414 or me
at (202) 551-3413 if you have questions rega rding comments on the financial statements
and related matters.  Please contact Jerard  Gibson, Attorney-Advi sor, at (202) 551-3473
or Sonia Gupta Barros at (202) 551-3655 with any other questions.

Brett White
CB Richard Ellis Group, Inc. July 1, 2010
Page 3

                                                                                                Sincerely,

Cicely LaMothe
                                                                                    Branch Chief