Mail Stop 3561

      							March 20, 2006

Mr. Wallace Macmillan
Chief Financial Officer
Central European Media Enterprises Ltd.
Clarendon House, Church Street, Hamilton
HM CX Bermuda

	Re:	Central European Media Enterprises Ltd.
      Form 10-K for Fiscal Year Ended December 31, 2005
		Filed March 2, 2006
		File No. 0-24796

Dear Mr. Macmillan:

      We have reviewed your filing and have the following
comments.
We have limited our review to only your financial statements and
related disclosures and do not intend to expand our review to
other
portions of your documents.  Please address the following comments
in
future filings.  If you disagree, we will consider your
explanation
as to why our comment is inapplicable or a future revision is
unnecessary.  Please be as detailed as necessary in your
explanation.
In some of our comments, we may ask you to provide us with
information so we may better understand your disclosure.  After
reviewing this information, we may or may not raise additional
comments.

	Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.



Form 10-K for Fiscal Year Ended December 31, 2005

Item 7.  Management`s Discussion and Analysis of Financial
Condition
and Results of Operations, page 47

1. We note your definition of the terms spot revenue and non-spot
revenue and the use of these terms throughout your MD&A
discussion.
Please confirm that these measures are based on your U.S. GAAP
results for the periods presented.  Additionally, since we are
unable
to recalculate the measures based on the information disclosed in
the
filing, please disclose a reconciliation showing how these
measures
reconcile to net revenue as presented in the financial statements.

IV. Analysis of the Results of Consolidated Operations, page 56
(d) Other Expenses items for the years ended December 31, 2005,
2004,
and 2003, page 61

2. We note that your foreign currency gain of $37.9 million arose
primarily as a result of the translation of the Euro-denominated
Senior Notes into US dollars at December 31, 2005.  Tell us more
specifically to what this gain relates and how you considered SFAS
52
when recording this gain in your consolidated statement of
operations.  Further, tell us how your accounting reconciles to
your
accounting policy disclosed on page 91.

VI. Critical Accounting Policies and Estimates, page 72

3. We note that your discussion regarding program rights, goodwill
and intangible assets, and long lived assets valuations does not
address the quantitative value of your assumptions and their
sensitivity to change.  Since critical accounting estimates and
assumptions are based on matters that are highly uncertain, you
should analyze their specific sensitivity to change, based on
other
outcomes that are reasonably likely to occur and would have a
material impact on your financial condition or results of
operations.
Revise your disclosures to provide quantitative as well as
qualitative disclosure when quantitative information is reasonably
available and will provide material information for investors.

	For additional guidance, refer to Item 303 of Regulation S-K
as
well as Part Five 	of the 	Commission`s Interpretive Release on
Management`s Discussion and 	Analysis of Financial Condition and
Results of Operation which is located on our 	website at:
http://www.sec.gov/rules/interp/33-8350.htm.




Report of Independent Registered Public Accounting Firm, page 78

4. We note that your auditors, Deloitte & Touche LLP are located
in
the U.K.  It appears that a majority of your assets, liabilities,
revenues and expenses relate to operations located in Central
Europe,
and that no substantial operations are located in the U.K.
Furthermore, it appears that your principal corporate offices are
located in Bermuda.  The staff interprets Article 2 of Regulation
S-X
to require the report on the financial statements of a registrant
that is not a foreign private issuer to be rendered ordinarily by
an
auditor licensed in the United States.  This interpretation
relates
to both U.S. incorporated registrants and foreign-incorporated
registrants that do not meet the foreign private issuer
definition.
However, in certain cases the staff will not object to the use of
a
foreign audit firm in cases where there is a logical relationship
between the location of the auditor and the location of the
registrant`s corporate offices or place where the registrant
conducts
its principal operations.   As a result, please tell us why you
engaged a U.K. auditor, as opposed to a U.S. public accounting
firm
or accounting firm located in Central Europe where the majority of
your operations are conducted.  We may have further comment.

Organization and Business, page 86

5. We note that prior to January 23, 2006 you use equity
accounting
to account for your 49% voting interest in Slovenska Televiszna
Spolocnost s.r.o. (STS).  We also note on page 6 that you share
70%
of the total profits of STS.  Tell us in detail how you considered
FIN 46R with respect to your investment in STS.

Consolidated Statements of Operations and Comprehensive Income,
page
81

6. Please revise your statements of operations to separately
present
cost and expenses applicable to net revenues in accordance with
Rule
5-03 of Regulation S-X.  In this regard, it appears from your
statement that, at a minimum, your cost of revenues should include
your operating costs and cost of programming.  With respect to
your
depreciation of property, plant and equipment and amortization of
intangibles, please comply with SAB Topic 11:B.

5. Senior Notes, page 101

7. We refer to your senior notes issued on May 5, 2005 and your
disclosure that the amounts outstanding are guaranteed by certain
of
your subsidiaries and are secured by a pledge of shares of those
subsidiaries and an assignment of certain contractual rights.
Tell
us how you considered Rule 3-10 of Regulation S-X.


*    *    *    *

      Please respond to these comments within 10 business days or
tell us when you will provide us with a response.  Please furnish
a
letter that keys your responses to our comments and provides any
requested information.  Detail letters greatly facilitate our
review.
Please understand that we may have additional comments after
reviewing your responses to our comments.

	We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings to be certain that the
filing includes all information required under the Securities
Exchange Act of 1934 and that they have provided all information
investors require for an informed investment 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
disclosure in the filings;

* staff comments or changes to disclosure in response to staff
comments do not foreclose the Commission from taking any action
with
respect to the filings; and

* the company may not assert staff comments 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 our review of your filings or
in
response to our comments on your filings.

      You may contact Inessa Berenbaum, Staff Accountant, at (202)
551-3371 or Kyle Moffatt, Accountant Branch Chief, at (202) 551-
3836
if you have questions regarding comments on the financial
statements
and related matters.  Please contact me at (202) 551-3810 with any
other questions.

								Sincerely,



								Larry Spirgel
								Assistant Director
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Mr. Macmillan
Central European Media Enterprises Ltd.
March 20, 2006
Page 4



UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549

         DIVISION OF
CORPORATION FINANCE