January 12, 2006

Mail Stop 3561

Via US Mail and Facsimile

Mr. Carl G. Schmidt
Vice President, Chief Financial Officer and Treasurer
201 N. Harrison Street, Suite 600
Davenport, Iowa 52801

Re:	Lee Enterprises, Incorporated
	Form 10-K for the year ended September 30, 2005
	Commission file #: 001-06227

Dear Mr. Schmidt:

We have reviewed the above referenced filing and have the
following
comments.  Where indicated, we think you should revise your
document
in response to these comments.  If you disagree, we will consider
your explanation as to why our comment is inapplicable or a
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 supplemental 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 September 30, 2005

Management`s Discussion and Analysis

- Continuing Operations, page 17

1. We note that on page 19 you disclose that you believe, absent
unusual tax settlements, the effective income tax rate will
decline
in 2006 due to the initiation of the Federal manufacturing credit
and
changes in the expected makeup of its income from continuing
operations before income taxes.  Please explain to us and discuss
in
MD&A in future filings the nature and amount of the expected
changes
in the makeup of income from continuing operations before income
taxes.  Also, explain why these changes in income from continuing
operations are expected to impact your effective income tax rate
for
2006.

2. We note that "other operating costs" is 30% of total operating
costs.  Please quantify for us the significant components of
"other
operating costs.  In future filings, please expand your MD&A
disclosure to discuss each of the significant components of "other
operating costs" and any significant variances in those components
from year to year.

- Operating Expenses and Results of Operations, page 18

3. Tell us and revise MD&A in future filings to discuss the nature
and amounts of the "transition costs" recognized in the Company`s
financial statements during 2005 in connection with the Pulitzer
acquisition.

- Overall Results, pages 19 and 22

4. We note the disclosure indicating that the Company`s income tax
expense was reduced by $1,200,000 in 2004 due to the favorable
resolution of tax issues during the period. Please tell us and
revise
MD&A in future filings to explain in further detail the nature of
tax
issues that were resolved favorably during 2004 and explain how
these
matters impacted the Company`s tax provision during the period. We
may have further comment upon receipt of your response.

Financial Statements

Consolidated Statements of Income and Comprehensive Income

5. We note your presentation of "operating income, before equity
in
earnings of associated companies" and "operating income" which
includes the equity in earnings of associated companies.  Please
tell
us why you believe it is appropriate to include equity in earnings
of
associated companies as part of operating income.  Note that we do
not generally believe that such amounts should be considered part
of
operating income under Rule 5-03(b)(13) of Regulation S-X but
rather
as a component of other income (expense).  Also, revise future
filings to eliminate the subtotal "operating income, before equity
in
earnings of associated companies" as we do not believe
presentation
of this subtotal is appropriate or in accordance with generally
accepted accounting principles or Regulation S-X.




Notes to the Financial Statements

Note 1. Significant Accounting Policies

- Accounts Receivable, page 41

6. We note that in 2005 your accounts receivable balance has
nearly
doubled in amount.  In future filings, please expand your
disclosure
of your policy for accounts receivable by including your policy
for
charging off uncollectible receivables and your policy for
determining past due or delinquency status (i.e., whether past due
status is based on how recently payments have been received or
contractual terms).  See paragraph 13a-c of SOP 01-6.

- Property and Equipment, page 42

7. We note your disclosure that you capitalize interest as a
component of the costs of constructing major facilities.  Please
disclose in future filings the amount of capitalized interest.
See
paragraph 21 of SFAS 34.

- Uninsured Risks, page 44

8. We note that you maintain a reserve for self-insurance of
health
care, workers compensation, and certain long-term disability costs
of
your employees.  In future filings, please revise Note 18.
Valuation
and Qualifying Accounts to disclose the changes in the reserves
related to your self insurance obligations, to the extent the
amounts
are material.

Note 2.  Acquisitions

- Acquisition of Pulitzer, page 44

9. We note your disclosure that on June 3, 2005 you acquired
Pulitzer
and each share of Pulitzer`s Common Stock and Class B Common Stock
was converted into the right to receive an amount equal to $64 per
share.  Please revise to disclose the nature and the amount of the
total consideration paid to complete the merger.  Also, revise to
disclose the primary reasons for the acquisition, including the
factors that contributed to a purchase price that resulted in
recognition of goodwill.  See paragraph 51 of SFAS No. 141.

10. We note from the disclosure in Note 2 that you are using a
useful
life of 21 years for purposes of amortizing the customer lists
acquired in the Pulitzer acquisition to expense. Please tell us in
further detail how you determined the estimated useful life for
this
intangible asset. As part of your response, please explain the
various factors that were considered in determining that a 21 year
useful life is appropriate and explain why you believe you will
continue to derive benefits from this intangible for a period of
21
years.
      We may have further comment upon review of your response.

Note 4. Investments in Associated Companies

11. We note the disclosure indicating that the Company converted
its
notes receivable from CityXpress to common stock during 2004.
Please
tell us and revise the notes to your financial statements to
disclose
the carrying amount of the notes that were converted into
CityXpress
common stock and indicate the conversion price used to convert the
notes into common stock. As part of your response you should also
explain how the conversion price used was determined and indicate
whether a gain or loss was recorded in connection with this
transaction in accordance with SFAS No.15 or other applicable
accounting literature. We may have further comment upon receipt of
your response.

Note 13. Stock Ownership Plans

12. Please tell us and clarify in the notes to your financial
statements the accounting treatment used with respect to the
cancellation and reissuance of 40,000 shares of restricted common
stock issued to an officer of the Company during 2004.

Report on Form 8-K/A dated June 3, 2005

13. We note that the report on Form 8-K/A dated June 3, 2005
included
pro forma financial information giving effect to the acquisition
of
Pulitzer. We also note from our review of this Form 8-K that the
pro
forma financial information included in this report on Form 8-K
did
not include adequate disclosure regarding the various assumptions
used to determine the pro forma adjustments. In future filings,
disclose all significant assumptions used to determine the pro
forma
adjustments. As part of these disclosures, please indicate the
nature
and amounts assigned to the various categories of intangible
assets
acquired and disclose the useful lives used to calculate
amortization
associated with each category of intangibles. You should also
disclose both the amount of debt obtained to fund the transaction
and
the amount repaid as well as the interest rates used to calculated
any related pro forma adjustments to interest expense.






Reports on Form 8-K dated November 14, 2005 and December 7, 2005

14. We note that you present the non-GAAP measures "diluted EPS,
excluding costs related to acquisition of Pulitzer" and "earnings
per
share, as adjusted" in your reports on Form 8-K dated November 14,
2005 and December 7, 2005, respectively. As outlined in ASR 142,
per
share data other than that related to net income, net assets and
dividends should be avoided in reporting financial results.
Furthermore, as outlined in footnote 11 of FR-65 per share
measures
that are prohibited specifically under GAAP or Commission rules
continue to be prohibited in materials filed with or furnished to
the
Commission. For example, see paragraph 33 of SFAS No.95 which
prohibits the disclosure of cash flow per share. Please confirm
that
you will eliminate disclosure of these non-GAAP earnings per share
measures in future filings.


* * * * * * * * * * * * * * * * * * * * * * *

As appropriate, please respond via EDGAR to these comments within
10
business days or tell us when you will provide us with a response.
Please furnish a cover letter that keys your responses to our
comments and provides any requested supplemental information.
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 filings reviewed by the staff to be
certain
that they have provided all information investors require for an
informed 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 filing; 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 filing or in response to
our comments on your filing.

You may contact Claire Erlanger at 202-551-3301 or me at 202-551-
3813
if you have questions.

								Sincerely,



								Linda Cvrkel
								Branch Chief
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Mr. Carl G. Schmidt
Lee Enterprises
January 12, 2006
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