May 14, 2010

United States Securities and Exchange Commission

Division of Corporation Finance

100 F Street, NE

Washington, D.C. 20549-6010

Attention: Sonia Gupta Barros

Dear Ms. Barros:

Reference is made to the comments of the Staff of the United States Securities and Exchange Commission (the “SEC” or the “Staff”) with respect to the above referenced annual report on Form 10-K for the fiscal year ended December 31, 2009 (the “Form 10-K”) of CB Richard Ellis Group, Inc. (the “Company”) in a letter dated May 3, 2010. We have considered the Staff’s comments and set forth below are the Staff’s comments and the Company’s responses.

For convenience of reference, we have set forth your comments in italics below, with the Company’s response following each comment.

General

Company Response

Noted.

Item 7. Management’s Discussion and Analysis of Financial Condition and Results of Operations

Critical Accounting Policies, page 38

Company Response

When the Company performed its required annual goodwill impairment review as of October 1, 2009, it determined that no impairment existed as the estimated fair value of its reporting units was in excess of their carrying value. Although economic conditions remained weak for most of 2009 and the Company’s full year revenues for 2009 declined when compared to the prior year, the Company did note early signs of an economic recovery taking place in the latter part of 2009. This was evidenced by several indicators, including the Company’s stock price ($13.57 per share on December 31, 2009 and $10.94 per share on October 1, 2009 versus $4.32 per share at December 31, 2008), a return to positive economic growth in the United States in the second half of 2009 and an economic rebound in the Asia Pacific region with transaction activity beginning to revive in late 2009. These indicators, as well as the benefit of cost reduction measures implemented in the second half of 2008 and 2009, led to a significant increase in the estimated fair value of the Company’s reporting units as of October 1, 2009 as compared to the prior year. In addition, the overall size of the Company’s goodwill and other non-amortizable assets being tested were sharply reduced as a result of a $1.2 billion impairment charge recorded during the year ended December 31, 2008. This impairment charge included the write-off of goodwill in its entirety in two reporting units that were most severely hit by the weak economic conditions at that time (i.e. Global Investment Management and Development Services).

In summary, the Company affirms its conclusion that no impairment of goodwill or other non-amortizable intangible assets existed for 2009. The Company will enhance its disclosure in its Annual Report on Form 10-K for the year ended December 31, 2010 to indicate what its conclusions relative to testing goodwill and other non-amortizable intangible assets were based upon.

Liquidity and Capital Resources, page 56

Company Response

The Company does not have any material legal or economic restrictions on transferring funds from its domestic and foreign subsidiaries. Although the Company could generally repatriate earnings from its foreign subsidiaries, it currently elects not to do so given income tax considerations, which the Company has already disclosed in its 2009 Annual Report on Form 10-K. Based on these facts, the Company respectfully submits to the Staff that no additional disclosure is warranted.

Significant Indebtedness, page 63

Company Response

The Company applies Financial Accounting Standards Board (“FASB”) Accounting Standards Codification (“ASC”) Topic 860-10-40 when accounting for transactions entered into under the funding arrangements of the ASAP Program with Fannie Mae. Sales of the 99% interest in the loans to Fannie Mae are recorded as a secured borrowing during the repurchase period with no gain or loss recognized as the ASAP Program requires the Company to repurchase the transferred assets before their maturity. A sale is recorded upon full delivery back to Fannie Mae via whole loan execution or securitization into a mortgage backed security since the Company has received consideration from the purchaser and has surrendered complete control over the loans.

Consolidated Statements of Operations, page 75

Company Response

Rule 3-09 of Regulation S-X requires separate financial statements of equity method investees to be filed with the Company’s Annual Report on Form 10-K if (i) an investment in an unconsolidated subsidiary exceeds 20% of the Company’s total assets, or (ii) if the Company’s share of income from continuing operations before provision for income taxes (“income”) from an investment in an unconsolidated subsidiary exceeds 20% of the Company’s total income. Rule 3-09 of Regulation S-X cross references Rule 1-02(w) relative to performing these tests and such rule prescribes the use of the average of the Company’s income for the last five fiscal years, excluding loss years, in instances where the income of the registrant for the most recent fiscal year is at least 10 percent lower than the average of the income for the last five fiscal years.

In regards to the first test, the Company’s total assets at December 31, 2009 were approximately $5.0 billion, of which only approximately $136.0 million, or 2.7%, were attributable to the Company’s total investments in unconsolidated subsidiaries. Therefore, this condition was not met.

In regards to the second test, the Company’s five-year average income (excluding losses in 2008 and 2009), totaling approximately $295.0 million, was used as prescribed by Rule 1-02(w), given that the Company’s income for the year ended December 31, 2009 was more than 10% lower than the five-year average income. There were no instances noted in which the Company’s share of income or loss from any of its investments in unconsolidated subsidiaries exceeded $59.0 million, which is equivalent to 20% of the Company’s five-year average income. It should also be noted that the Company’s ownership interest in its investments in unconsolidated subsidiaries is generally lower than 50% and in many investments is less than 5%.

In conclusion, based on the above mentioned facts, the Company affirms its conclusion that inclusion of separate financial statements of equity method investees was not required in its 2009 Annual Report on Form 10-K.

Item 15. Exhibit and Financial Statement Schedules, page 148

3. Exhibits

Company Response

The Company did not include all of the exhibits and schedules listed in the table of contents for exhibits 10.1(a), 10.1(b), 10.1(c), 10.1(e), and 10.1(h) because this information is ministerial in form and does not provide any material or meaningful disclosure in addition to the underlying agreements. While this has been a common practice of issuers, the Company understands that Item 601(b)(10) of Regulation S-K does not provide an exemption permitting the exclusion of this information. The Company respectfully proposes to the Staff that it will file the complete agreement (including schedules and exhibits listed in the table of contents) for exhibits 10.1(e) and 10.1(h) as an exhibit to its Quarterly Report on Form 10-Q for the period ended June 30, 2010. The Company proposes to make no changes to the filings for exhibits 10.1(a), 10.1(b) and 10.1(c) because these agreements have been superseded by exhibits 10.1(e) and 10.1(h) and the materials omitted would largely be duplicative and of no further relevance. Exhibits 10.1(a), 10.1(b) and 10.1(c) will not be included in our Form 10-K for the year ended December 31, 2010.

Schedule III – Real Estate Investments and Accumulated Depreciation, page 150

Company Response

The Company’s largest individual project on Schedule III as of December 31, 2009 included approximately $78 million of gross real estate, which represents only 1.5% of the Company’s total assets. Given this fact, the Company respectfully submits to the Staff that it does not believe that it has any material projects and no additional disclosure is required in Schedule III. However, if the Company invests in a material project in the future, it will include additional disclosure in Schedule III at that time.

Aggregate rental revenue and associated operating expenses of $59.9 million and $34.3 million, respectively, were recognized from the Company’s portfolio of real estate during the year ended December 31, 2009. This represented only approximately 1.4% of the Company’s total revenue and only approximately 2.5% of the Company’s total operating expenses. While the Company does not believe these operations are material to its business, the Company will enhance its disclosure in the Business Section of its Annual Report on Form 10-K for the year ended December 31, 2010 to include additional relevant information about its real estate portfolio, including property type, geographic diversification and rental revenues.

As requested by the Staff, the Company acknowledges that:

In the event you have any additional questions, please contact me directly at (310) 405-8909.