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April 24, 2009

VIA EDGAR

U.S. Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

Attention:     Mr. Kyle Moffatt

    Re:

    Clear Channel Outdoor Holdings, Inc. (the “Company”)
Form 10-K for the fiscal year ended December 31, 2008, filed March 2, 2009
File No. 001-32663

Dear Mr. Moffat:

     This letter is in response to the Staff’s comments to the Company by its letter dated April 3,
2009 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.

Item 1. Business

Sources of Revenues, page 5

    1.

    We note that for all of your billboards in the United States, you use independent third
party-auditing companies to verify the number of impressions delivered by a display. Please
tell us how you utilize this information.

The Traffic Audit Bureau (“TAB”) is a tri-party consortium funded by advertisers, advertising
agencies and the outdoor industry. The TAB compiles the daily effective circulation (“DEC”), which
is based on traffic count, of a particular display. This information is posted on-line and is
available to TAB members. The information supplied by TAB is one of the factors for determining
the pricing of a particular display and is used as a sales resource. Generally, the more
impressions a display delivers, the higher the rate. In addition, the TAB also audits sales
proposals to determine if the DEC’s contained in the proposal are accurate. These selected audits
ensure that the outdoor advertising data is presented to potential advertising customers
consistently across the various competitors.

Item 7. Management’s Discussion and Analysis of Financial Condition and Results of
Operations

Americas Results of operations, page 43

International Results of operations, page 44

    2.

    Please revise to discuss how you expect customer cancellations and non-renewals during the
fourth quarter to impact each of your segments prospectively in 2009.

Securities and Exchange Commission

April 24, 2009

Page 2 of 13

The Company is unable to estimate the impact customer cancellations and non-renewals will have on
its segments prospectively in 2009 because the factors that affect cancellations and non-renewals
continue to be in a state of flux which makes future visibility uncertain. However, the Company
states on page 36 under Description of Business, “Our outdoor advertising business has been, and
may continue to be, adversely impacted by the difficult economic conditions currently present in
the United States and other countries in which we operate. The continuing weakening economy has,
among other things, adversely affected our clients’ need for advertising and marketing services,
resulted in increased cancellations and non-renewals by our clients, thereby reducing our occupancy
levels and could require us to lower our rates in order to remain competitive, thereby reducing our
yield, or affect our client’s solvency. Any one or more of these effects could materially affect
our business, financial condition and results of operations.”

    3.

    Tell us the source and nature of the significant increase in bad debt in the Americas’
business, particularly after your merger. Per schedule set forth on page 107, you reported a
significant increase in the allowance for doubtful accounts during the period from July 31
through December 31, 2008.

Approximately $17 million of the reserve for bad debt after the merger was attributable to the
Company’s America’s segment. Approximately $4 million was attributable to deterioration in agings
based on our standard policies and the remainder due to payment concerns on specific national
agency accounts primarily in the automotive and retail advertising categories.

    4.

    We note your disclosure that direct operating expenses increased as a result of new site
lease contracts for both the Americas and the International segments. In light of the fixed
and long-term nature of these expenses, it is unclear to us how direct operating expenses
decreased sequentially during the third and fourth quarters of 2008 as set forth in Note O.
Please advise.

Direct operating expenses increased approximately $5 million in the Company’s Americas segment
during the period noted. However, the increase was offset by a direct operating expense decline in
the Company’s International segment. This decline was attributable to movements in foreign
exchange. On a constant dollar basis (as defined on page 37), direct operating expenses in the
Company’s International segment would have increased approximately $2.5 million during the period
noted.

Cash Flows, page 46

    5.

    We note that in lieu of a discussion and analysis of cash flows, you merely recited net
changes in the major captions in the Statements of Cash Flows. Please provide an enhanced
analysis and explanations of the sources and uses of cash and material changes in particular
items underlying the major captions as reported therein for all periods presented.

The Company will add the following disclosure to the Form 10-K:

Investing Activities

     2008

Securities and Exchange Commission

April 24, 2009

Page 3 of 13

     We spent $175.8 million in our Americas segment for the purchase of property, plant and
equipment mostly related to the construction of new billboards. We spent $182.5 million in our
International segment for the purchase of property, plant and equipment mostly related to new
billboard and street furniture contracts and renewals of existing contracts.

     Our Americas segment paid $55.1 million for the acquisition of advertising structures and the
final earnout payments for Interspace Airport Advertising, which we acquired in July 2006. Our
International segment paid $41.4 million primarily related to the acquisition of additional equity
interests in outdoor companies and the acquisition of advertising structures.

     We also received proceeds of $41.5 million from asset sales, $34.2 million of which was from
the disposal of land and buildings in our International segment.

     2007

     We spent $142.8 million in our Americas segment for the purchase of property, plant and
equipment mostly related to construction of new billboards. We spent $132.9 million in our
International segment for the purchase of property, plant and equipment mostly related to new
billboard and street furniture contracts and renewals of existing contracts.

     During 2007, our Americas segment paid $39.5 million in cash primarily to acquire display
faces. In addition, our International segment paid $29.6 million, which includes the acquisition
of an outdoor advertising business in Romania, additional equity interests in outdoor companies and
the acquisition of advertising structures.

     2006

     We spent $90.5 million in our Americas segment for the purchase of property, plant and
equipment mostly related to construction of new billboards. We spent $143.4 million in our
International segment for the purchase of property, plant and equipment mostly related to new
billboard and street furniture contracts and renewals of existing contracts.

     We completed the acquisition of Interspace on July 1, 2006 and paid cash consideration of
$76.5 million. In addition our Americas segment acquired display faces for $55.4 million in cash.
Our International segment acquired display faces and additional equity interests in outdoor
companies for $105.7 million, including the acquisition of an outdoor advertising business in the
United Kingdom.

Financing Activities

     2008

     Net cash used in financing activities of $232.8 million for 2008 reflected a net reduction in
debt and credit facilities of $67.6 million and net transfers of cash to Clear Channel
Communications of $169.2 million. The net transfers of cash to Clear Channel Communications
represent the activity in the “Due from/to Clear Channel Communications” account. This

Securities and Exchange Commission

April 24, 2009

Page 4 of 13

activity primarily relates to working capital and settlement of interest on the cash
management notes and the $2.5 billion note payable to Clear Channel Communications.

     2007

     Net cash used in financing activities of $305.8 million for 2007 is primarily related to the
net transfer of cash to Clear Channel Communications of $302.9 million. The net transfers of cash
to Clear Channel Communications represent the activity in the “Due from/to Clear Channel
Communications” account. This activity primarily relates to working capital and settlement of
interest on the cash management notes and the $2.5 billion note payable to Clear Channel
Communications.

     2006

     Net cash used in financing activities of $53.2 million for 2006 principally reflects a net
reduction in debt of $59.7 million. The net transfers of cash to Clear Channel Communications
represent the activity in the “Due from/to Clear Channel Communications” account. This activity
primarily relates to working capital and settlement of interest on the cash management notes and
the $2.5 billion note payable to Clear Channel Communications.

Debt with Clear Channel Communications, pages 49-50

    6.

    We note that you maintain collection bank accounts which are swept daily into accounts of
Clear Channel Communications. Per your disclosure, unlike the management of cash from your
U.S. based operations, the amount of cash, if any, which is transferred from your foreign
operations to Clear Channel Communications is determined on a “basis mutually agreeable” to
you and Clear Channel Communications based on the “reasonable foreseeable cash needs of your
foreign operations.” Addressing existing and known or reasonably likely future cash
requirements of your foreign operations, please disclose the nature of such needs which are
evaluated regularly for cash management purposes.

The Company will add the following disclosure to its Form 10-K:

“The Company’s foreign operations forecast their cash needs to satisfy general working capital
requirements and capital expenditures. The Company’s foreign operations also evaluate anticipated
cash flows from various investing activities. Therefore, to the extent that anticipated cash on
hand from the Company’s foreign operations is not enough to satisfy its cash needs, the foreign
operations will either borrow from local credit facilities that may be available to those
operations or the Company will transfer required funds to its foreign operations. However, the
Company’s $150.0 million sub-limit facility is not currently available as Clear Channel
Communications drew the remaining availability on February 6, 2009. To the extent that cash on
hand from the Company’s foreign operations exceeds its cash needs, the foreign operations may repay
local credit facilities (which could include the $150.0 million sub-limit) or the Company may
repatriate that cash for use domestically.”

Securities and Exchange Commission

April 24, 2009

Page 5 of 13

Critical Accounting Estimates, page 55

Indefinite-lived Assets, page 56

    7.

    We note that indefinite-lived intangibles which consist of billboard permits accounted for
19% of total assets as of December 31, 2008. In light of the significance of the remaining
indefinite-lived intangibles’ balance, we expect robust and comprehensive disclosure in your
critical accounting policies regarding your impairment testing policy. This disclosure should
provide investors with sufficient information about management’s insights and assumptions with
regard to the recoverability of your billboard permits. Specifically, we believe you should
provide the following information:

    •

    Provide a more detailed description of the steps you perform to review your billboard
permits for recoverability.

The Company has responded to this Staff comment by providing a marked excerpt of the Form 10-K.
Please see Attachment A.

    •

    Describe the nature of the valuation techniques you employed in performing the
impairment tests. Qualitatively and quantitatively describe in more detail the significant
estimates and assumptions used in your valuation model to determine the fair value of each
unit of accounting under your direct valuation method and how you derive “industry
normalized information.” For example, you should disclose at a minimum your assumptions
with respect to market revenue growth rates, market share, profit margin, duration and
profile of the build-up period, how estimated start-up capital costs and losses incurred
during the build-up period were determined, the risk adjusted discount rates and terminal
values. Discuss your consideration of any market risk premiums.

The Company has responded to this Staff comment by providing a marked excerpt of the Form 10-K.
Please see Attachment A.

    •

    Describe changes to the assumptions and methodologies, if any, since your annual
impairment test. In addition, tell us how the assumptions in your most recent test were
impacted by the current economic environment. For example, you should explain in detail
how your discount rates reflect the market risk premiums that have been noted in the
current equity and debt markets.

The Company has responded to this Staff comment by providing a marked excerpt of the Form 10-K.
Please see Attachment A.

    •

    Further, disclose any changes to your units of accounting or allocations of building
permits by unit of accounting and the reasons for such changes.

There were no changes to the Company’s units of accounting.

    •

    Provide a table showing:

Securities and Exchange Commission

April 24, 2009

Page 6 of 13

    1.

    the carrying value and the fair value of each unit of accounting. Alternatively,
if you do not disclose the fair value of each unit of accounting, you should disclose
its fair value if it does not exceed its carrying value by a significant amount; and

The Company has responded to this Staff comment by inserting “The fair value of our permits equaled
their carrying value after recognition of the non-cash impairment charge.” Please see Attachment
A.

    2.

    using hypothetical percentage reductions in fair value, disclose the impairment
amount that would have occurred had the hypothetical reduction in fair value existed at
the time of your impairment testing.

The Company has responded to this Staff comment by providing a marked excerpt of the Form 10-K.
Please see Attachment A.

    •

    In addition, if the fair value of any of your units of accounting does not, or would
not, exceed its carrying value by a significant amount, provide a sensitivity analysis of
your most recent impairment test assumptions for this unit of accounting based upon
reasonable likely changes similar to what was already provided for you billboard permits
balance on page 57.

The fair value of the Company’s billboard permits equaled their carrying value after recognition of
the non-cash impairment charge. The unit of accounting for the Company’s billboard permits is the
market level. The table on page 57 was produced based on the effect of 100 basis point declines in
the discrete and terminal period revenue growth rate, profit margin and discount rate assumptions
for each unit of accounting.

    8.

    Explain how you determined your units of accounting including your basis for concluding that
separately recorded indefinite-lived intangibles should be combined into a single unit of
accounting for purposes of testing impairment. In this regard, tell us more about your
impairment testing at the “market level” and provide us with your analysis of EITF 02-7.

The Company determined that its billboard permits should be combined into a single unit of
accounting at the market level after consideration of