Mail Stop 0308

							April 12, 2005



Thomas P. Benson
Chief Financial Officer
CKX, Inc.
650 Madison Avenue
New York NY  10022


	RE:	CKX, Inc.
		Item 4.01 Form 8-K filed April 7, 2005
            	File No. 0-17436


Dear Mr. Benson:

          We have reviewed the above referenced filing and have
the
following comments.  We welcome any questions you may have about
our
comments.  Feel free to contact us at the telephone numbers listed
at
the end of this letter.

1. We do not believe the statement that you replaced your former
auditors is substantially the same as saying you dismissed them,
if
true.  Please revise to use the term, "dismissed" if true.  See
Item
304(a)(1)(i) of Regulation S-K.

2. It is suggested that the third paragraph be revised to state
what
subsequent interim period you are referring to and to use the
singular form of that period.  Please note that there is only one
subsequent interim period; that is, the period from the end of the
most recent fiscal year through the date of dismissal, if true.

3. Please tell us if Deloitte has accepted the engagement.  Your
disclosure that the Board approved Deloitte may not be the same as
their immediate acceptance.  If this process has not been
finalized,
you may want to revise the disclosure to clarify this fact.






Thomas Benson
CKX, Inc.
April 12, 2005
Page 2



      We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing 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
disclosures in the filing;

* 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 this action 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 connection with our review of
your
filing or in response to our comments on your filing.


	The amendment requested above should be filed within five
business days from the date of this letter or we should be advised
by
that date when it will be filed.  The amendment should include an
updated letter from your former accountants indicating that they
have
read the Form 8-K/A.  Please file your response to these comments
as
an EDGAR correspondence file at the same time as you file the Form
8-
K/A.  Any questions regarding the above should be directed to me
at
(202) 942-1809, or in my absence, to Robert Benton at (202) 942-
1811.

							Sincerely,



							Robert Burnett
						            Staff Accountant


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