Mail Stop 4561 December 19, 2005 Mr. Peter S. Rummell Chief Executive Officer The St. Joe Company 245 Riverside Avenue, Suite 500 Jacksonville, FL 32202 Re: The St. Joe Company Form 10-K for Fiscal Year Ended December 31, 2005 Form 10-Q for Fiscal Quarter Ended March 31, 2005 Form 10-Q for Fiscal Quarter Ended June 30, 2005 File No. 1-10466 Dear Mr. Rummell: We have completed our review of your Form 10-K and related filings and do not, at this time, have any further comments. Sincerely, Steven Jacobs Accounting Branch Chief