Mail Stop 0407

      							August 10, 2005

Mr. Jacques Mallette
Executive Vice President and Chief Financial Officer
Quebecor Media Inc.
612 St. Jacques Street
Montreal, Quebec, Canada H3C 4M8

	Re:	Quebecor Media Inc.
      Form 20-F for Fiscal Year Ended December 31, 2004
		Filed March 31, 2005
		File No. 333-13792

Dear Mr. Mattette:

      We have reviewed your supplemental response letter dated
July
8, 2005 as well as your filing and have the following comments.
As
noted in our comment letter dated June 7, we have limited our
review
to your financial statements and related disclosures and do not
intend to expand our review to other portions of your documents.

Operating lease arrangements, page 88

1. Please refer to prior comment #5.  Please confirm to us that
your
guaranteed residual values are recognized on a straight-line basis
over the lease term.  If not, tell how you are accounting for
guaranteed residual values and the basis for your accounting under
US
GAAP.

Consolidated Statements of Income, page F-1

2. Please refer to prior comment #2.  Since "Operating income
before
undernoted items," is not either required or expressly permitted
by
the standard-setter that establishes Canadian GAAP, delete this
line
item from your consolidated statements of income.  If you elect to
continue to present this non-GAAP measure in your selected
financial
data section, please comply with Item 10(e) of Regulation S-K.


Note 24. Significant Differences between GAAP in Canada and in the
United States, page F-61

3. Please refer to prior comment #10.  It appears to us that your
tangible long-lived assets have finite lives.  Therefore, it
appears
to us that a reasonable estimate of your asset retirement
obligation
can be made, since SFAS 143 considers the various uncertainties
that
you have discussed with regard to your asset retirement
obligations.
For example:

?	With regard to your inability to determine a potential range
of
settlement dates for your access to the support structures, we
believe that a probability weighted assessment can adequately
address
the uncertainty with regard to the amount and timing of the future
cash flows necessary to settle the liability.  Note that renewals
within your control should also be included in the range of
expected
settlement dates, assuming you have plans to renew those leases.
?	With regard to the probability of enforcement of the
remediation
clauses, SFAS 143 indicates that uncertainty about whether
performance will be required does not defer the recognition of a
retirement obligation; rather, that uncertainty is factored in to
the
measurement of the fair value of the liability through assignment
of
probabilities to cash flows.  Refer to paragraphs A5, A17-A18 and
C10-C12 of SFAS 143.

      Please advise or revise accordingly.

*    *    *    *

      Please respond to these comments within 10 business days or
tell us when you will provide us with a response.  You may contact
Dean Suehiro, Senior Staff Accountant, at (202) 551-3384 or Kyle
Moffatt, Accountant Branch Chief, at (202) 551-3836 if you have
questions regarding comments on the financial statements and
related
matters.  Please contact me at (202) 551-3810 if you have any
other
questions.


								Sincerely,



								Larry Spirgel
								Assistant Director
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Mr. Jacques Mallette
Quebecor Media Inc.
August 10, 2005
Page 2



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

         DIVISION OF
CORPORATION FINANCE