Mail Stop 7010

      November 23, 2005



Mr. John G. O`Rourke
Senior Vice President - Finance and Chief Financial Officer
The GEO Group, Inc.
621 NW 53rd Street, Suite 700
Boca Raton, Florida 33487

	RE: 	Form 10-K for the Fiscal Year ended January 2, 2005
                    	Forms 10-Q for the Fiscal Quarters ended
April 3, 2005, July 3,
		2005 and October 2, 2005
                    	File No. 1-14260


Dear Mr. O`Rourke:

		We have reviewed your response letter dated November 18,
2005 and have the following additional comments.  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.

	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 October 2, 2005

Item 4 - Controls and Procedures, page 33

You stated that disclosure controls and procedures were effective
in
timely alerting you to material information that is required to be
included in your periodic SEC filings.  Please note that you have
provided an incomplete definition of disclosure controls and
procedures per Rules 13a-15(e) and 15d-15(e) of the Exchange Act.
Please revise in future filings your definition to clarify, if
true,
that your disclosure controls and procedures were effective to "to
ensure that information required to be disclosed in [your] filings
under the Securities Exchange Act of 1934 is recorded, processed,
summarized and reported within the time periods specified in the
Securities and Exchange Commission rules and forms."  Please also
clarify in future filings your definition to also clarify, if
true,
that your disclosure controls and procedures were effective to
ensure
that information required to be disclosed by you in the reports
that
you file or submit under the Exchange Act is accumulated and
communicated to your management, including your principal
executive
and principal financial officers, or persons performing similar
functions, as appropriate to allow timely decisions regarding
required disclosure.  Please show us what your revised disclosure
would look like.



*    *    *    *



      		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 response on EDGAR
as
a correspondence file.  Please understand that we may have
additional
comments after reviewing your responses to our comments.

       	If you have any questions regarding these comments,
please
direct them to Gus Rodriguez, Staff Accountant, at (202) 551-3752
or,
in his absence, Rufus Decker, the undersigned, at (202) 551-3769.



          						Sincerely,



								Rufus Decker
								Branch Chief
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John G. O'Rourke
The GEO Group, Inc.
November 23, 2005
Page 1 of 2



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

         DIVISION OF
CORPORATION FINANCE