Mail Stop 3561

      							December 20, 2005

Via U.S. Mail and Fax
Mr. Robert C. Bateman
Chief Financial Officer
Fisher Communications, Inc.
100 4th Avenue N. Suite 510
Seattle, WA  98109

	RE:	Fisher Communications, Inc.
      Form 10-K for Fiscal Year Ended December 31, 2004
		Filed March 25, 2005
		Forms 10-Q for Fiscal Quarter Ended September 30, 2005
		File No. 0-22439

Dear Mr. Bateman:

      We have reviewed your filings and have the following
comments.
We have limited our review to only your financial statements and
related disclosures and do not intend to expand our review to
other
portions of your documents.  Please address the following comments
in
future filings.  If you disagree, we will consider your
explanation
as to why our comment is inapplicable or a future revision is
unnecessary.  Please be as detailed as necessary in your
explanation.
In some of our comments, we may ask you to provide us with
information so we may better understand your disclosure.  After
reviewing this information, we may or may not raise additional
comments.

	Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or any other aspect
of
our review.  Feel free to call us at the telephone numbers listed
at
the end of this letter.




      Form 10-K for the year ended December 31, 2004
      Note 1 - Operations and Accounting policies

      Recent accounting pronouncements, page 54

1. We note your statement that historically you have accounted for
acquisitions of the broadcasting operations using the residual
method.  Further you state that you are unable to predict the
impact
of EITF D-108. Then in subsequent 10-Qs you state that you do not
have any intangible asset originally valued using the residual
value.
Please clarify this inconsistency.  Further based on previous
reviews
we are aware that you used the residual method.  Tell us whether
for
purposes of your impairment test you have used a direct value
method
on all intangible assets that were previously valued using the
residual method in accordance with EITF D-108.  Revise or advise.

*    *    *    *

      Please respond to these comments within 10 business days or
tell us when you will provide us with a response.  Please furnish
a
letter that keys your responses to our comments and provides any
requested information.  Detailed letters greatly facilitate our
review.  Please file your letter on EDGAR.  Please understand that
we
may have additional comments after reviewing your responses to our
comments.

	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 all information required under the Securities
Exchange Act of 1934 and that they have provided all information
investors require for an informed investment decision.  Since the
company 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 connection with responding to our comments, please
provide,
in writing, a statement from the company acknowledging that

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

* 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.

      In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in our review of your filings or
in
response to our comments on your filings.

      You may contact Gopal Dharia, Staff Accountant, at (202)
551-
3353 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 me at (202) 551-3810 with any
other
questions.

								Sincerely,

      Larry Spirgel
								Assistant Director
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Mr. Robert Bateman
Fisher Communications, Inc.
January 9, 2006
Page 1



UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549

         DIVISION OF
CORPORATION FINANCE