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corresp

June 26, 2007

VIA EDGAR

U.S. Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

Attention:     Mr. Larry Spirgel

    Re:

    Clear Channel Outdoor Holdings, Inc. (the “Company”)

Form 10-K for the fiscal year ended December 31, 2006, filed March 1, 2007

File No. 1-32663

Dear Mr. Spirgel:

     This letter is in response to the Staff’s comments to the Company by its letter dated May 30,
2007 relating to the above-referenced Form 10-K. Our responses are referenced to the applicable
Staff comment and the paragraph numbering used for each response set forth below corresponds to the
paragraph numbering used in the Staff’s comment letter.

Form 10-K for the fiscal year ended December 31, 2006

Item 8. Financial Statements and Supplementary Data

Note H — Commitments and Contingencies, page 68

    1.

    We note your response to prior comment 3. In future filings, please disclose your accounting
policy for rentals that include renewal options, annual rental escalation clauses and minimum
franchise payments, and maintenance related to displays by providing the details included in
your response.

    The Company will include the following disclosure in its 2007 Form 10-K:

    The Company accounts for its rentals that include renewal options, annual rental escalation
clauses, minimum franchise payments and maintenance related to displays under the guidance
in EITF 01-8, SFAS 13, SFAS 29 and FTB 85-3.

    The Company considers its non-cancelable contracts that enable it to display advertising on
buses, taxis, trains, bus shelters, etc. to be leases in accordance with the guidance in
EITF 01-8. These contracts may contain minimum annual franchise payments which generally
escalate each year. The Company accounts for these minimum franchise payments on a
straight-line basis in accordance with FTB 85-3. If the rental increases are not scheduled
in the lease, for example an increase based on the CPI, those rents are considered contingent rentals and are
recorded as expense when accruable. Other contracts may contain a variable rent component

Securities and Exchange Commission

June 26, 2007

Page 2 of 3

    based
on revenue. The Company accounts for these variable components as contingent rentals under SFAS
29, and records these payments as expense when accruable.

    The Company accounts for annual rental escalation clauses included in the lease term on a
straight-line basis under the guidance in FTB 85-3. The Company considers renewal periods
in determining its lease terms if at inception of the lease there is reasonable assurance
the lease will be renewed. Expenditures for maintenance are charged to operations as
incurred, whereas expenditures for renewal and betterments are capitalized.

    Most of the Company’s advertising structures are on leased land. In addition, the Company
leases certain facilities and equipment. The Company accounts for these leases in
accordance with the policies described above.

    2.

    We note your response to prior comment 4. In future filings, please expand upon your
disclosures providing the details included in your response. Also tell us and disclose if
there are any penalties or other consequences of not fulfilling these commitments and if you
have currently or historically encountered any violations of these contracts.

    Certain of the Company’s contracts contain penalties for not fulfilling its commitments related
to its obligations to build bus stops, kiosks and other public amenities or advertising
structures. Historically, the Company has met its commitments and has not incurred any
penalties due to not fulfilling its commitments.

    The Company will include the following disclosure in its 2007 Form 10-K:

    The Company’s contracts with municipal bodies or private companies relating to street furniture,
billboard, transit and malls generally require the Company to build
bus shelters, kiosks and other
public amenities or advertising structures during the term of the contract. The Company owns
these structures and is generally allowed to advertise on them for the remaining term of the
contract. Once the Company has built the structure, the cost is capitalized and expensed over
the shorter of the economic life of the asset or the remaining life of the contract.

    Certain of the Company’s contracts contain penalties for not fulfilling its commitments related
to its obligations to build bus shelters, kiosks and other public amenities or advertising
structures. Historically, any such penalties have not materially impacted the Company’s
financial position or results of operations.

*     *     *     *

               In connection with responding to the Staff’s comments, the Company acknowledges that:

    •

    the Company is responsible for the adequacy and accuracy of the disclosure in the
filings;

Securities and Exchange Commission

June 26, 2007

Page 3 of 3

    •

    Staff comments or changes to disclosure in response to Staff comments do not foreclose
the Commission from taking any action with respect to the filings; 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.

               If you have any questions regarding these responses, please contact Herb Hill at (210)
822-2828.

    Very truly yours,

    /s/ Herbert W. Hill, Jr.

    Herbert W. Hill, Jr.

    Senior Vice President and Chief Accounting
Officer

    cc:

    Randall T. Mays

President and Chief Financial Officer