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                 June 16, 2023

       Stephen D. Lebovitz
       Chief Executive Officer
       CBL & ASSOCIATES PROPERTIES INC
       CBL Center, Suite 500
       2030 Hamilton Place Blvd.
       Chattanooga, Tennessee 37421-6000

                                                        Re: CBL & ASSOCIATES
PROPERTIES INC
                                                            Registration
Statement on Form S-3
                                                            Filed June 9, 2023
                                                            File No. 333-272563

       Dear Stephen D. Lebovitz:

              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 Victor Rivera Melendez at 202-551-4182 or Ruairi
Regan at 202-551-
       3269 with any questions.




                 Sincerely,


                 Division of Corporation Finance

                 Office of Real Estate & Construction
       cc:                                              Steven R. Barrett, Esq.