July 8, 2019

Lynn A. Feldman, Esq.
Executive Vice President and General Counsel
Clear Channel Outdoor Holdings, Inc.
99 Park Avenue, Second Floor
New York, New York 10016

       Re: Clear Channel Outdoor Holdings, Inc.
           Registration Statement on Form S-3
           Filed on July 2, 2019
           File no. 333-232517

Dear Ms. Feldman:

       This is to advise you that we have not reviewed and will not review your
registration
statement.

        Please refer to Rules 460 and 461 regarding requests for acceleration.
We remind you
that the company and its management are responsible for the accuracy and
adequacy of their
disclosures, notwithstanding any review, comments, action or absence of action
by the staff.

       Please contact Paul Fischer at 202-551-3415 with any questions.



                                                            Sincerely,

                                                            Division of
Corporation Finance
                                                            Office of
Telecommunications
cc:    James S. Rowe