SecProbe.io

Mail Stop 3720

May 16, 2016

Robert H. Walls, Jr.
Executive Vice President and General Counsel
Clear Channel Outdoor Holdings, Inc.
200 East Basse Road, Suite 100
San Antonio, Texas   78209

Re: Clear Channel Outdoor Holdings, Inc.
 Form 10 -K for Fiscal Year Ended December 31, 201 5
Filed February 25, 2016
File No. 1 -32663

Dear Mr. Walls :

We have reviewed your filing and have the following comments.  Please comply with the
following  comments in future filings.  Confirm in writing that you will do so and explain to us
how you intend to comply.  In some of our comments, we may ask you to provide us with
information so we may better understand your disclosure.

Please respond to these c omments  within ten busine ss days by providing the requested
information or advis e us as soon as possible when you will respond.  If you  do not believe our
comments apply to your facts and circumstances , please tell us why in your response.

After reviewi ng your response to these comments, we may have additional comments.

Note s to Consolidated  Financial  Statements

Note 7. Income Taxes, page 102

1. Please disclose the U.S. income (loss) before income tax expense (benefit), pursuant to
Rule 4 -08(h)(i) of Regulation S -X.

2. Please tell us the amount of undistributed earnings of foreign subsidiaries and how you
complied with the disclosure requirements of ASC 740 -30-50-2.

We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing includes the information the Securities Exchange Act of

Robert H. Walls, Jr.
Clear Channel Outdoor Holdings, Inc.
May 16, 2016
Page 2

 1934 and all applicable Exchange Act rules require.   Since the compa ny 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 provide a written statement from the co mpany
acknowledging that:

 the company is responsible for the adequacy and accuracy of the disclosure 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 federal securities laws of the United States.

You may contact Christy Adams, Senior Staff Accountant,  at (202)  551-3363  or Ivette
Leon, Assistant Chief Accountant, at (202) 551 -3351 if you have questions regarding comments
on the financial statements and related matters.  Please contact Paul Fischer, Staff Attorney at
(202) 551 -3415  or me at (202) 551 -3810  with any other questions.

Sincerely,

 /s/ Terry French for

 Larry Spirgel
Assistant Director
AD Office 11 – Telecommunications

cc: Lauren E. Dean
 Vice President, Associate General Counsel and Assistant Secretary