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 May 6, 2025

David J. Sailer
Executive Vice President and Chief Financial Officer
Clear Channel Outdoor Holdings, Inc.
4830 North Loop 1604 West, Suite 111
San Antonio, TX 78249

 Re: Clear Channel Outdoor Holdings, Inc.
 Form 10-K for Fiscal Year Ended December 31, 2024
 Item 2.02 Form 8-K filed May 1, 2025
 File No. 001-32663
Dear David J. Sailer:

 We have reviewed your filings and have the following comment(s).

 Please respond to this letter within ten business days by providing the
requested
information or advise us as soon as possible when you will respond. If you do
not believe a
comment applies to your facts and circumstances, please tell us why in your
response.

 After reviewing your response to this letter, we may have additional
comments.

Form 10-K for Fiscal Year Ended December 31, 2024
Consolidated Statements of Loss, page 49

1. Please tell us your consideration of separately presenting revenue and
direct operating
 expenses associated with tangible products, services and leasing
activities, if they
 represent more than 10% of total revenue in any period presented.
Revenue for items
 that represents less than 10% of total revenue may be aggregated with
revenue for
 other items that also represents less than 10% of total revenue. Direct
operating
 expenses should be combined in the same manner as the related revenue.
Refer to
 Rules 5-03.1 and 5-03.2 of Regulation S-X.
 May 6, 2025
Page 2

Note 3 - Dispositions and Discontinued Operations
Discontinued Operations, page 60

2. Please tell us your consideration of disclosing the total operating and
investing cash
 flows, the depreciation and amortization, and significant operating and
investing
 noncash items of the discontinued operation for the periods in which the
results of
 operations of the discontinued operation are presented in the statement
where net
 income is reported. Refer to ASC 205-20-50-5B(c).
Item 2.02 Form 8-K filed May 1, 2025
Adjusted EBITDA, page 5

3. Your presentation of total segments adjusted EBITDA on page 5 appears to
be a non-
 GAAP measure and should be reconciled to its most directly comparable
GAAP
 measure. However, once reconciled it would appear such measure may
include
 adjustments that are inconsistent with the applicable non-GAAP guidance.
In this
 regard, adjusting for corporate expenses appears to present a non-GAAP
measure that
 excludes normal, recurring, cash operating expenses. Therefore, please
revise to
 remove this measure from your earnings releases. Refer to Item
10(e)(1)(i)(B) of
 Regulation S-K and Questions 104.04 and 100.01 of the Non-GAAP Financial
 Measures Compliance and Disclosure Interpretations.
 We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence
of action by the staff.

 Please contact Valeria Franks at 202-551-7705 or Suying Li at
202-551-3335 with
any questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Trade &
Services
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