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SEC Company Response from Clear Channel Outdoor Holdings, Inc. (CCO) (CIK 0001334978) (CCO) — Nov 9, 2005

Clear Channel Outdoor Holdings, Inc. (CCO) (CIK 0001334978)
Date: Nov. 9, 2005 · CIK: 0001334978 · Accession: 0000950129-05-010785

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File numbers found in text: 333-127375

Referenced dates: October 27, 2005

Date
November 9, 2005
Author
/s/ Daryl L. Lansdale, Jr.
Form
CORRESP
Company
Clear Channel Outdoor Holdings, Inc. (CCO) (CIK 0001334978)

Letter

Fulbright & Jaworski L.L.P.

A Registered Limited Liability Partnership

300 Convent Street, Suite 2200

San Antonio, Texas 78205-3792

www.fulbright.com

dlansdale@fulbright.com

telephone:

(210) 224-5575

direct dial: (210) 270-9367

facsimile:

(210) 270-7205

November 9, 2005

Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Mail Stop 0308

Washington, D.C. 20549

Attention: Ted Yu

Re:

Clear Channel Outdoor Holdings, Inc.

Registration Statement on Form S-1

File No. 333-127375

Ladies and Gentlemen:

Clear Channel Outdoor Holdings, Inc. (the “Company”) has filed its Registration Statement on Form S-1 relating to the initial public offering of shares of its Class A Common Stock. We previously provided information to you by letter dated October 27, 2005 regarding the Company’s Reserved Share Program (the “Program”) to be conducted by Merrill Lynch, Pierce, Fenner & Smith Incorporated. Pursuant to an oral request from the Staff, we hereby confirm to you that there have been no material changes to the Program materials since the review conducted by Cecilia Blye, Esq. of the Office of the General Counsel of the Division of Corporation Finance.

If any member of the Staff has any questions concerning these matters or needs additional information or clarification, he or she should contact the undersigned at (210) 224-5575.

Very truly yours,
/s/ Daryl L. Lansdale, Jr.

Show Raw Text
CORRESP
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corresp

Fulbright & Jaworski L.L.P.

A Registered Limited Liability Partnership

300 Convent Street, Suite 2200

San Antonio, Texas 78205-3792

www.fulbright.com

    dlansdale@fulbright.com

    telephone:

    (210) 224-5575

    direct dial: (210) 270-9367

    facsimile:

    (210) 270-7205

November 9, 2005

Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Mail Stop 0308

Washington, D.C. 20549

Attention: Ted Yu

    Re:

    Clear Channel Outdoor Holdings, Inc.

    Registration Statement on Form S-1

    File No. 333-127375

Ladies and Gentlemen:

     Clear Channel Outdoor Holdings, Inc. (the “Company”) has filed its Registration Statement on
Form S-1 relating to the initial public offering of shares of its Class A Common Stock. We
previously provided information to you by letter dated October 27, 2005 regarding the Company’s
Reserved Share Program (the “Program”) to be conducted by Merrill Lynch, Pierce, Fenner & Smith
Incorporated. Pursuant to an oral request from the Staff, we hereby confirm to you that there have
been no material changes to the Program materials since the review conducted by Cecilia Blye, Esq.
of the Office of the General Counsel of the Division of Corporation Finance.

     If any member of the Staff has any questions concerning these matters or needs additional
information or clarification, he or she should contact the undersigned at (210) 224-5575.

Very truly yours,

/s/ Daryl L. Lansdale, Jr.

Daryl L. Lansdale, Jr.

    cc:

    John Tippit (Clear Channel Communications, Inc.)

John W. White (Cravath, Swaine & Moore LLP)

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