Mail Stop 7010

      December 22, 2005


Mr. James P. Dietz
Chief Financial Officer
WCI Communities, Inc.
24301 Walden Center Drive
Bonita Springs, FL  34134

	RE:	Form 10-K for the fiscal year ended December 31, 2004
		Form 10-Q for the quarter ended June 30, 2005
		File No. 1-31255

Dear Mr. Dietz:

      We have limited our review of the above referenced reports
to
the presentation of distributions from investments in joint
ventures
in the statement of cash flows, as well as your revised
calculations
of capitalized interest.  If you disagree with a comment, we will
consider your explanation as to why our comment is inapplicable or
a
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-Q FOR THE PERIOD ENDED JUNE 30, 2005

Financial Statements

Note 1 - Basis of Presentation, page 4

1. We note your response to prior comment 3.  We disagree with
your
quantitative assessment of materiality and believe that the
financial
statements included in your Form 10-K for the year ended December
31,
2004 and subsequent Form 10-Qs should be restated to appropriately
apply SFAS 34.  In this regard, we note that the impact of
appropriately applying SFAS 34 results in material quantitative
adjustments to your Traditional Homebuilding segment`s gross
margins.
You may wish to provide us with additional detailed analysis which
presents the quantitative impact of appropriately applying SFAS 34
to
your consolidated homebuilding gross margins as well as your Tower
Homebuilding segment`s gross margins if you believe such analysis
will further assist us in understanding how you reached the
conclusion that this misstatement is not quantitatively material.
Please note however that we also do not agree with your belief
that,
from a qualitative perspective, the application of interest
capitalization required a significant amount of judgment and
estimates.  It does not appear to us that your exclusion of the
vertical construction expenditures on your traditional
homebuilding
and the underlying land costs for each tower was as a result of
improper estimation; rather, you did not appropriately identify
these
homebuilding assets as qualifying assets under SFAS 34.
*    *    *    *

      Please respond to these comments within 10 business days, or
tell us when you will provide us with a response.  Please provide
us
with a response letter that keys your responses to our comments
and
provides any requested information.  Detailed letters greatly
facilitate our review.  Please file your supplemental response on
EDGAR as a correspondence file.  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 reviewed by the staff to
be
certain that they have provided all information required under the
Securities Exchange Act of 1934 and 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 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 filing
or
in response to our comments on your filing.

      If you have any questions regarding these comments, please
direct them to Jeffrey Gordon, Staff Accountant, at (202) 551-3866
or, in his absence, Jeanne Baker, Assistant Chief Accountant, at
(202) 551-3691.

							Sincerely,



							Rufus Decker
							Accounting Branch Chief


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Mr. James P. Dietz
WCI Communities, Inc.
December 22, 2005
Page 1 of 3




UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-7010

         DIVISION OF
CORPORATION FINANCE