SecProbe.io

September 1, 2010

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
 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 with  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 advi sing us when you will provide the requested
response.  If you do not believe our comments apply to your fact s and circumstances or do not
believe an amendment is appropriate, pl ease tell us why in your response.
 After reviewing any amendment to your filing and the information you provide in
response to these comments, we ma y have additional comments.

General

1. We note that in response to comment six in  our letter dated May 3, 2010 you have filed
the schedules to your Second Amended and Rest ated Credit Agreement as Exhibit 10.1 to
your Quarterly Report for the quarterly period ended June 30, 2010 and requested
confidential treatment for info rmation included in those schedules.  We will respond to
your request for confidential treatment by separate  letter.  Please note that we will not be
in a position to clear our review of your a nnual report for the fiscal year ended December
31, 2009 until we have cleared comments, if any, on your confidential treatment request.

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

DEFINITIVE PROXY ON SCHE DULE 14A FILED APRIL 19, 2010

Executive Compensation

Compensation Discussion and Analysis

Our 2009 Compensation Program, page 24
 Elements of our compensation program, page 26

 2. We have considered your response to comment three in our prior letter dated July 1, 2010
and reissue that comment in part.  Please br iefly tell us why the committee determined
that each executive achieved their strategic measures at the leve l you indicated in your
response.  For example, you indicate that Mr. White achieved a total of 96% of his
strategic measures.  Please briefly discuss why the committee concl uded that he achieved
96%.  Please confirm you will provide similar disclosure in future filings.    We urge all persons who are responsible for th e accuracy and adequacy of the disclosure
in the filing to be certain that the filing include s the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules requir e.  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 responding to our comments, please provi de a written statement from the company
acknowledging that:
• the company is responsible for the adequacy and accuracy of the disclo sure in the filing;

• staff comments or changes to disclosure in response to staff comments 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 federa l securities laws of  the United States.

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

You may contact Jorge Bonilla, Staff Account ant, at (202) 551-3414 or Cicely Lamothe,
Accounting Branch Chief, at (202) 551-3413 if  you have questions regarding the financial
statements and related matters.  Please contac t Jerard Gibson, Attorney-Advisor, at (202) 551-
3473 or the undersigned at (202) 551-3655 with any other questions.
         S i n c e r e l y ,

Sonia Gupta Barros Special Counsel