May 30, 2025

David J. Sailer
Executive Vice President and Chief Financial Officer
Clear Channel Outdoor Holdings, Inc.
4830 North Loop 1604 West, Suite 111
San Antonio, TX 78249

        Re: Clear Channel Outdoor Holdings, Inc.
            Form 10-K for Fiscal Year Ended December 31, 2024
            Response dated May 20, 2025
            File No. 001-32663
Dear David J. Sailer:

       We have reviewed your May 20, 2025 response to our comment letter and
have the
following comment(s).

       Please respond to this letter within ten business days by providing the
requested
information or advise us as soon as possible when you will respond. If you do
not believe a
comment applies to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to this letter, we may have additional
comments.
Unless we note otherwise, any references to prior comments are to comments in
our May 6,
2025 letter.

Form 10-K for Fiscal Year Ended December 31, 2024
Consolidated Financial Statements
Consolidated Statements of Loss, page 49

1.     We read your response to prior comment 1. We note on page 65 you
disclose revenue
       from leases of $499.6 million, $675.5 million, and $672.7 million for
fiscal years
       2024, 2023, and 2022, respectively. Please present revenues and direct
operating
       expenses associated with services, leasing activities, and tangible
products separately
       on the face of your consolidated statement of loss, if they present more
than 10% of
       total revenues in any period presented. Revenues for items that
represent less than
       10% of total revenues may be aggregated with revenues for other items
that also
       represent less than 10% of total revenues. Direct operating expenses
should be
       combined in the same manner as the related revenues. Refer to Rules
5-03.1 and 5-
       03.2 of Regulation S-X.
 May 30, 2025
Page 2

       Please contact Valeria Franks at 202-551-7705 or Suying Li at
202-551-3335 with
any questions.



                                                         Sincerely,

                                                         Division of
Corporation Finance
                                                         Office of Trade &
Services