SecProbe.io

May 5, 2011
 Gil Borok Chief Financial Officer CB Richard Ellis Group, Inc. 11150 Santa Monica Blvd
Suite 1600
Los Angeles, CA 90025
Re: CB Richard Ellis Group, Inc.
Form 10-K for Fiscal Year Ended December 31, 2010 Filed March 1, 2011 File No. 001-32205

Dear Mr. Borok:
 We have reviewed your filing and have the following comments.  In our comments, we
may ask you to provide us with informati on 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.

Gil Borok
CB Richard Ellis Group, Inc. May 5, 2011 Page 2

Form 10-K

 Item 7. Management’s Discussion and Analys is of Financial Condition and Results of
Operations
 Critical Accounting Policies

 Real Estate

 Cost Capitalization and Allocation, page 36

 1. Please tell us if you capital ize internal costs incurred when acquiring, developing and
constructing real estate assets.  To the extent  you capitalize such costs, please tell us the
amount of these indirect costs capitali zed for each fiscal year presented.
 Results of Operations, page 39

 2. We note your EBITDA, as adjusted disclosu re.  Please tell us how you have complied
with Item 10(e)(1)(i )(C) of Regulation S-K, or tell us how you determined it was not
necessary to include a statement disclosing the reasons why management believes that
presentation of the this non-GAAP financia l measure provides useful information to
investors.
 Liquidity and Capital Resources, page 48

 3. Tell us your consideratio n of providing liquidity  disclosures to discuss the potential tax
impact associated with the repatriation of undi stributed earnings of non-U.S. subsidiaries.
In this regard, consider disclosing the amount  of cash that is currently held by your non-
U.S. subsidiaries and disclose the impact of repatriating the undi stributed earnings of
non-U.S. subsidiaries. Please refer to Item 303(A)(1) of Regulation S-K and Section IV
of our Release 33-8350.

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 an d 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

Gil Borok
CB Richard Ellis Group, Inc. May 5, 2011 Page 3

• 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.

You may contact Jennifer Moni ck, Senior Staff Accountan t, at 202-551-3295 or me at
202-551-3629 if you have questions.
Sincerely,

Kevin Woody Branch Chief