SecProbe.io

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                         CALAMOS ASSET MANAGEMENT, INC.

                               October 1, 2004

VIA ELECTRONIC TRANSMISSION

Mr. William Friar
Senior Financial Analyst
Securities and Exchange Commission
Division of Corporation Finance
450 Fifth Street, N.W.
Washington, D.C.  20549

                         Calamos Asset Management, Inc.
                               File No. 333-117847
            Responses to SEC Comment Letter dated September 24, 2004

Dear Mr. Friar:

            On behalf of Calamos Asset Management, Inc. (the "Company"), set
forth below are the comments of the staff of the Securities and Exchange
Commission (the "Commission") received in your letter dated September 24, 2004
relating to Amendment No. 1 ("Amendment No. 1") to the Company's registration
statement on Form S-1 (File No. 333-117847) filed on August 2, 2004 (as amended
to date, the "Registration Statement"), including the prospectus contained
therein (the "Prospectus"). Each comment is followed by the Company's response
to that comment. Capitalized terms used but not defined herein have the meanings
assigned to them in the Registration Statement.

            This letter should be read in conjunction with the accompanying
Amendment No. 2 to the Registration Statement ("Amendment No. 2"), which the
Company filed with the Commission on the date hereof. In this letter, all page
references set forth in the Company's responses to the staff's comments refer to
page numbers in Amendment No. 2. To assist the staff in reviewing Amendment No.
2, we are delivering, by overnight mail to Mr. Clampitt, a copy of this letter
and eight bound copies of Amendment No. 2. Four of the copies of Amendment No. 2
have been marked to show changes from the Amendment No. 1.

            By its responses herein and in Amendment No. 2, the Company believes
that it has addressed all of the comments of the staff of the Commission. The
Company is aware of its obligations under the Securities Act and will request in
writing an acceleration of the effective date of the Registration Statement. At
such time, the Company will, pursuant to the staff's

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Mr. William Friar
October 1, 2004
Page 2

request, furnish a letter acknowledging the matters specified in the bullet
points included in the introductory paragraphs of your letter dated September
24, 2004.

General

      1.    The Company's failure to include key information in this amendment,
            such as the number of shares being sold, a pricing range for their
            sale, the percentage of the Company being sold, the cost to
            terminate EAU Plan, no final management services agreement, no
            future employment agreements with the senior managers and twenty-two
            missing exhibits may result in the staff requiring significant time
            after the filing of the next amendment to provide you with our
            comments, and we may have significant comments and there may be many
            of them pertaining to any part of the registration statement.

            The Company acknowledges the staff's comment and has included most
            of the key information requested by the staff, as well as most of
            the missing exhibits.

      2.    The current disclosures do not appear to address the distribution of
            current profits. Please revise the summary to indicate under
            "Reorganization" how it will be determined who is entitled to the
            current profits, i.e., profits in the year in which the
            reorganization occurs.

            The Company advises the staff that the stockholders of Calamos
            Family Partners, Inc. will be entitled to all net profits of Calamos
            Family Partners, Inc. recognized prior to the Reorganization. Net
            profits or losses of Calamos Holdings LLC recognized from and after
            the consummation of the Reorganization will be allocated to the
            members of Calamos Holdings LLC pro rata in accordance with the
            percentages of their respective equity interests. The Company has
            revised the disclosure on page 3 of the Prospectus to include this
            information.

Summary
Our Company

      3.    Revise the narrative after the penultimate paragraph to indicate the
            Company initiated paying supplemental compensation payments to
            selling agents and the date when that activity began. In addition,
            disclose the aggregate compensation paid to selling agents in the
            years ended December 31, 2001, December 31, 2003 and the period
            ending June 30, 2004 as well as the portion that was supplemental
            compensation during each of these periods.

            The Company submits that, because its supplemental compensation
            payments to third-party selling agents have been immaterial and
            declining as a percentage of assets under management and revenues
            and were not a contributing factor to the growth of the Company's
            assets under management, a discussion of such payments is not
            sufficiently material to investors in the Company's Class A

<PAGE>
Mr. William Friar
October 1, 2004
Page 3

            common stock to warrant including such a discussion in the "Summary"
            section of the Prospectus. However, in response to the staff's
            request, the Company has disclosed on page 46 of the Prospectus when
            it first began making supplemental compensation payments. The
            Company supplementally advises the staff that it did not initiate
            these payments; rather the Company began making them at the request
            of third-party selling agents. In addition, in response to the
            staff's request, the Company has disclosed in MD&A in each
            period-to-period discussion of operating expenses the amount of
            supplemental compensation payments paid to third-party selling
            agents (please see pages 51, 55 and 57 of the Prospectus). The
            Company supplementally advises the staff that each period-to-period
            discussion already quantifies distribution expense, which represents
            payments (other than supplemental compensation payments) to
            third-party selling agents for selling, underwriting, servicing and
            administering the mutual funds managed by the Company. The Company
            does not believe that aggregating distribution expense with
            supplemental compensation expenses (which is a component of
            marketing and sales promotion expense) would be meaningful to
            investors and therefore has not presented these amounts on an
            aggregate basis as requested by the staff.

Reorganization

      4.    With regard to your previous response number 9, please reconcile
            your answer that the Calamos Family Partners will not derive any
            revenues from the Company with the disclosure that the Company will
            lease the future headquarters from Calamos Family Partners as well
            as the yet to be filed Exhibit 10.9 (Management Services Agreement).
            If Calamos Family Partners will derive future revenues from the
            Company, provide disclosures of the nature and expected dollar
            amounts of such revenues.

            The Company confirms to the staff that it does not expect Calamos
            Family Partners, Inc. to derive any revenues from the Company. The
            Company advises the staff that, as disclosed on page 2 of the
            Prospectus in the second paragraph under "Summary - Reorganization,"
            pursuant to the Real Estate Distribution in June 2004, Calamos
            Family Partners, Inc. distributed to its stockholders its interest
            in all of its real estate assets, including the Company's existing
            corporate headquarters. The stockholders of Calamos Family Partners,
            Inc. thereafter contributed the real estate assets distributed to
            them to a new limited liability company, Calamos Property Holdings
            LLC, formed by them. That limited liability company is owned
            directly by the stockholders of Calamos Family Partners, Inc. It is
            not a subsidiary of Calamos Family Partners, Inc., and Calamos
            Family Partners, Inc. has no ownership interest, direct or indirect,
            in Calamos Property Holdings LLC.

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Mr. William Friar
October 1, 2004
Page 4

            Upon consummation of the offering, the Company expects to lease its
            existing headquarters from a subsidiary of Calamos Property Holdings
            LLC, and the Company also expects to lease its new headquarters,
            upon completion thereof, from a subsidiary of Calamos Property
            Holdings LLC. Calamos Family Partners, Inc. will not derive any
            revenues from the Company's lease payments to a subsidiary of
            Calamos Property Holdings LLC because Calamos Family Partners, Inc.
            has no ownership interest in Calamos Property Holdings LLC or any of
            its subsidiaries.

            The Company further advises the staff that all payments expected to
            be made under the Management Services Agreement will be made by
            Calamos Family Partners, Inc. to the Company as consideration for
            services provided by the Company. Calamos Family Partners, Inc.
            therefore will not derive revenues from the Company pursuant to this
            agreement.

The Offering
Use of Proceeds

      5.    We note your response that the Company plans to spend $30 million
            for equipping the new headquarters prior to moving in mid-2005.
            Please advise us why this is not a partial use of the proceeds from
            this offering. In addition, please disclose the other expected
            working capital uses.

            The Company confirms to the staff that it does not expect to use any
            of the proceeds of the offering to equip its new headquarters prior
            to moving in mid-2005. The Company currently has and, even if it did
            not consummate the offering, would expect to continue to have
            sufficient cash on hand to equip its new headquarters. The Company
            expects to use that cash, and not proceeds of the offering, for that
            purpose.

            The Company advises the staff that it currently is not able to
            identify specific working capital purposes for which it may use
            proceeds of the offering. The Company therefore has deleted from
            pages 6 and 27 of the Prospectus references to working capital
            as a potential use of proceeds and has revised the disclosure under
            "Use of Proceeds" on page 27 to add more detail about the expected
            use of proceeds.

Related to Our Industry
Our business and operations...

      6.    Revise the first narrative to use the penultimate sentence in the
            first paragraph as the caption. In addition, delete the broad
            discussion of how the Company is regulated to instead discuss the
            various material proposed or recently enacted regulations that have
            or could materially effect the business model of the Company. In
            addition, the Company's response did not address the question as

<PAGE>

Mr. William Friar
October 1, 2004
Page 5

            to whether or not any clients or company personnel "engaged in" any
            late trading or market timing activities. If so, please advise us of
            the details.

            The Company has revised the first risk factor on page 12 of the
            Prospectus to use the penultimate sentence of the first paragraph as
            the caption for the risk factor.

            Pursuant to discussions with the staff, the Company has not revised
            the risk factor in response to the second sentence of the staff's
            comment, but instead has added disclosure on page 12 of the
            Prospectus discussing indemnification for past violations of
            applicable laws and regulations.

            The Company supplementally advises the staff that it has policies
            and procedures to prevent and detect late trading and short-term,
            frequent trading. These policies and procedures include, among other
            things, redemption fees, multi-layer reviews and exchange
            limitations.

            With regard to late-trading, the Company is unaware of any
            shareholders that have been permitted to late-trade any shares of
            the open-end funds managed by the Company. All orders for purchases,
            redemptions or exchanges placed directly with the open-end funds
            must be received prior to the close of regular session trading on
            the New York Stock Exchange to receive that day's net asset value.
            Shares of open-end funds managed by the Company may be purchased,
            redeemed or exchanged through third-party selling agents. A
            third-party selling agent who accepts such orders as agent of the
            open-end funds must process those orders at the net asset value next
            determined after the receipt of the order. Although the Company
            cannot state with absolute certainty that no third-party selling
            agent has accepted a late-trade, the Company's contracts with
            third-party selling agents require that they adhere to the open-end
            fund's prohibition against late-trading, and the Company has no
            knowledge that any third-party selling agent has placed a late trade
            order with any open-end funds managed by the Company.

            With respect to short-term, frequent trading, the prospectuses of
            the open-end funds managed by the Company state, "The Funds are
            intended for long-term investment purposes only, and are not
            intended for short-term or excessive trading. These practices may
            disrupt portfolio management strategies and may increase expenses,
            and thus harm fund performance." The prospectuses further state that
            each "Fund may, in its discretion, suspend, and may permanently
            terminate, the trading or exchange privileges of any investor who
            engages in trading activity that it believes would be disruptive to
            the Fund." The open-end funds managed by the Company have in the
            past become aware of accounts that they believed to be engaged in
            short-term, frequent trading. In accordance with the funds'
            policies, they rejected or restricted those accounts. In fact, even
            prior to the regulatory focus on this issue that began in the fall
            of 2003, the open-end funds managed by the Company had restricted a
            number of accounts believed to
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Mr. William Friar
October 1, 2004
Page 6

            be engaged in short-term, frequent trading. In addition, as is
            disclosed in the Company's September 10, 2004 responses to the
            staff's prior comments on this matter, the Company has not entered
            into any agreements, whether formal or informal, to permit
            short-term, frequent trading in any of the funds that it manages.

Our profit margins...

      7.    Revise to use the second sentence as the caption. In addition,
            disclose the Company's fee structure as it compares to others in the
            industry.

            The Company has revised the second