Mail Stop 3561

      April 19, 2006

Via Fax and U.S. Mail

Michael F. Rickert
Vice President, Chief Accounting Officer, Treasurer and Assistant
Secretary
Discover Bank
12 Read`s Way
New Castle, Delaware 19720

Re:	Discover Card Master Trust I
	Amendment No. 1 Registration Statement on Form S-3
	Filed March 30, 2006
	File No. 333-131898

Dear Mr. Rickert,

      We have limited our review of your filing for compliance
with
Regulation AB.  Please note that our limited review covers only
those
issues addressed in the comments below.  Please also note that our
comments to either the base prospectus and/or the supplement
should
be applied universally, if applicable.

      Where indicated, we think you should revise your document in
response to these comments.  If you disagree, 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
supplemental information so that we can better understand your
disclosure.  After reviewing this information, we may raise
additional comments.

      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 and 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.






Registration Statement on Form S-3

Prospectus Supplement

Cover Page
1. We note your response to comment 9.  Item 1102(h) specifies
that
any credit enhancement "or other support" should be briefly
described
on the cover page, with reference to Item 1115.  Please revise as
appropriate.


*	*	*	*	*

      As appropriate, please amend your registration statement in
response to these comments.  You may wish to provide us with
marked
copies of the amendment to expedite our review.  Please furnish a
cover letter with your amendment that keys your responses to our
comments and provides any requested information.  Detailed cover
letters greatly facilitate our review.  Please understand that we
may
have additional comments after reviewing your amendment and
responses
to our comments.

	We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing to be certain that the
filing includes all information required under the Securities Act
of
1933 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 the facts relating to a
company`s
disclosure, they are responsible for the accuracy and adequately
of
the disclosures they have made.

	Notwithstanding our comments, in the event the company
requests
acceleration of the effective date of the pending registration
statement, it should furnish a letter, at the time of such
request,
acknowledging that:

* should the Commission or the staff, acting pursuant to delegated
authority, declare the filing effective, it does not foreclose the
Commission from taking any action with respect to the filing;

* the action of the Commission or the staff, acting pursuant to
delegated authority, in declaring the filing effective, does not
relieve the company from its full responsibility for the adequacy
and
accuracy of the disclosure in the filing; and

* the company may not assert staff comments and the declaration of
effectiveness 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.

	We will consider a written request for acceleration of the
effective date of the registration statement as a confirmation of
the
fact that those requesting acceleration are aware of their
respective
responsibilities under the Securities Act of 1933 and the
Securities
Exchange Act of 1934 as they relate to the proposed public
offering
of the securities specified in the above registration statement.
We
will act on the request and, pursuant to delegated authority,
grant
acceleration of the effective date.

      We direct your attention to Rule 461 regarding requesting
acceleration of a registration statement.  Please allow adequate
time
after the filing of any amendment for further review before
submitting a request for acceleration.  Please provide this
request
at least two business days in advance of the requested effective
date.

	If you have any questions regarding these comments, you may
contact Susan Min at (202) 551-3727.  If you need further
assistance,
you may contact me at (202) 551-3XXX.

								Sincerely,


								Sara Dunton
								Senior Attorney

cc:	Via Facsimile (312) 993-9767
	Ms. Kathy Birkeland, Esq.
	Latham & Watkins LLP
	Telephone: (312) 876-7700

Mr. Michael F. Rickert
Discover Card Master Trust I
April 19, 2006
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