December 21, 2005
VIA EDGAR
Securities and Exchange Commission
Division of Corporation Finance
450 Fifth Street, N.W.
Washington, D.C. 20549-0405
| Re: | Blockbuster Inc. |
| Form 10-K for the year ended December 31, 2004 |
| Form 10-Q for the quarter ended September 30, 2005 |
| File No. 001-15153 |
Ladies and Gentlemen:
In connection with responding to comments raised by the Staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) with respect to the Form 10-K for the year ended December 31, 2004 and Form 10-Q for the quarter ended September 30, 2005 of Blockbuster Inc., a Delaware corporation (the “Company”), the Company hereby acknowledges that:
| • | The Company is responsible for the adequacy and accuracy of the disclosure 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 Staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. |
| If you need additional information, please contact the undersigned at 214-854-3000. |
Very truly yours,
BLOCKBUSTER INC. | ||
| By: | /s/ James A. Howell | |
James A. Howell Senior Vice President and Corporate Controller | ||
