October 11,
2005


Mail Stop 4561

Andrew Jacobs
8401 North Central Expressway, Suite 800
Dallas, TX  75225

      Re:	Capstead Mortgage Corporation
		Form 10-K for the year ended December 31, 2004
		File No. 001-08896

Dear Mr. Jacobs:

      We have reviewed your response letter dated August 26, 2005
and
have the following additional comments.  As previously stated,
these
comments require amendment to the referenced filings previously
filed
with the Commission.

Form 10-K

Exhibit 13

Management`s Discussion and Analysis of Financial Condition and
Results of Operations

Results of Operations, page 38
1. We have read and considered your response to comment 4(a).  We
continue to believe the use of operating income and operating
income
per share is confusingly similar to other measures calculated
under
GAAP.  As such, please revise future filings accordingly to label
this measure in a manner that is dissimilar to descriptions used
under GAAP.
2. In reference to your response to comment 4(b), please revise
future filings to explain the reasons why management believes this
non-GAAP financial measure provides useful information to
investors
regarding the Company`s operating performance.  Your current
disclosure that operating income is used to determine the funds
available for reinvestment or distribution indicates that you are
using this as a measure of your liquidity.  Also tell us what
consideration was given to disclosing this non-GAAP information
separately from the other GAAP information included in your
Results
of Operations table under a heading clearly labeled as "Other
Data".
*    *    *    *

      As appropriate, please respond to these comments within 10
business days or tell us when you will provide us with a response.
Detailed cover letters greatly facilitate our review.  Please file
your cover letter on EDGAR.  Please understand that we may have
additional comments after reviewing your responses to our
comments.

      You may contact Yolanda Crittendon, Staff Accountant, at
(202)
551-3472 or the undersigned at (202) 551-3413 if you have
questions.




							Sincerely,



      Cicely Luckey
      Branch Chief


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Mr. Andrew Jacobs
Capstead Mortgage Corporation
October 11, 2005
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