Mail Stop 3561 March 15, 2006 Mr. J. Gordon Smith Chief Financial Officer Asbury Automotive Group, Inc. 622 Third Avenue, 37th Floor New York, New York 10017 RE: Asbury Automotive Group, Inc. Form 10-K for Fiscal Year Ended December 31, 2004 Filed March 15, 2005 Form 10-K/A for Fiscal Year Ended December 31, 2004 Filed March 15, 2006 Form 10-Q/A for Quarterly Period Ended March 31, 2005 Form 10-Q/A for Quarterly Period Ended June 30, 2005 Form 10-Q/A for Quarterly Period Ended September 30, 2005 File No. 001-31262 Dear Mr. Gordon: We have completed our review of your Form 10-K and related filings and have no further comments at this time. Please note that we limited our review of your filings to those issues we addressed in our comment letter dated January 18, 2006. Sincerely, George F. Ohsiek, Jr. Branch Chief