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                  [letterhead of Willkie Farr & Gallagher LLP]



VIA EDGAR


December 23, 2008


Securities and Exchange Commission
450 Fifth Street, N.W.
Judiciary Plaza
Washington, DC  20549
Attn:   Larry Spirgel
        Assistant Director

         Re:      Strayer Education, Inc.
                  Form 10-K for the Fiscal Year ended December 31, 2007
                  Filed February 14, 2008 (the "2007 Form 10-K")
                  File No. 0-21039
                  ----------------


Dear Mr. Spirgel:

     On behalf of Strayer Education, Inc. ("Strayer"), we respectfully submit
below Strayer's response to the comments of the staff (the "Staff") of the
Securities and Exchange Commission contained in your letter dated November 25,
2008 to Robert S. Silberman, Strayer's Chairman of the Board and Chief Executive
Officer. For your convenience, we have set forth below the Staff's comments in
italics, followed by Strayer's response thereto.

Definitive Proxy Statement Incorporated by Reference into Part III
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Compensation Discussion and Analysis, page 11 of Proxy Statement
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Identification and Analysis of 2007 Compensation Programs, page 13 of Proxy
Statement
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1.   We note that you did not disclose the corporate financial targets set by
     your Board in connection with the annual bonus plan because they are
     confidential. If you believe that disclosure of corporate financial targets
     for completed fiscal years is not required because it would result in
     competitive harm such that you may omit this information under Instruction
     4 to Item 402(b) of Regulation S-K, please provide in your response letter
     a detailed explanation of such conclusion. If you believe you have a
     sufficient basis to keep the information confidential, disclose in future
     filings how difficult it would be for the executive or how likely it would
     be for you or a business unit to achieve the undisclosed targets. General
     statements regarding the level of difficulty or ease associated with
     achieving the goals are not sufficient. In discussing how difficult it will
     be for an executive or how likely it will be for you or a business unit to
     achieve the performance goals, provide as much detail as necessary without
     providing information that would result in competitive harm. Refer to
     Regulation S-K Compliance and


<PAGE>

Securities and Exchange Commission
December 23, 2008
Page 2

     Disclosure Interpretations, Question and Answer 118.04, available at
     www.sec.gov/divisions/corpfin/guidance/regs-kinterp.htm.

     Although we continue to believe that certain corporate financial targets
     considered by the Compensation Committee should be treated as confidential,
     as the disclosure of such targets would result in competitive harm to the
     Company, the principal reason for non-disclosure of such financial targets
     is that no single financial target is itself material to the Compensation
     Committee's determination of bonus amounts.

     As discussed in the disclosure incorporated in the 2007 Form 10-K, the
     bonus determination with respect to our named executive officers is made on
     a discretionary basis by the Compensation Committee, subject to the further
     approval of the Board. While the Compensation Committee considers various
     factors in determining the level of any bonus payable, including the
     achievement of certain corporate financial targets, ultimately, no one
     factor is dispositive, or even material, to the determination process. For
     2007, the Compensation Committee considered a wide variety of factors in
     its discretionary determination, including five separate financial targets
     (revenue, operating margin, EBIT, net income and earnings per share), and
     numerous other non-financial targets, including targets relating to new
     campus openings, operations in new states, compliance, regulatory
     approvals, performance of the Company's online business, increases in
     corporate and institutional customers, academic improvement measures and
     other operational performance measures, as well as capital redeployment
     steps. While the Compensation Committee believes that each of the various
     targets is itself relevant to its determination of bonus amounts, the
     achievement of any one target, or for that matter, any particular
     combination of factors, would not result in a specific bonus amount being
     paid to the Company's named executive officers.

     Once the Compensation Committee has evaluated the Company's relative
     performance with respect to each of the targets listed above, to the extent
     that it believes that such performance warrants bonus amounts to be paid to
     the named executive officers generally, the Compensation Committee then
     evaluates each named executive officer's individual performance for the
     year, and specifically with respect to relative contribution each executive
     made toward the achievement of the Company goals described above, or to the
     extent such goals were not achieved, whether any executive
     disproportionally contributed to such non-achievement. The Compensation
     Committee generally sets target bonus amounts for Senior Vice Presidents
     and above at 75% of such executive's base salary, and for Vice Presidents,
     at 40% of base salary, which the Compensation Committee believes provides a
     good framework for establishing internal pay equity among its executives,
     while maintaining the discretion to pay a higher bonus when the
     Compensation Committee believes either or both corporate or individual
     performance warrants. As provided in the Summary Compensation Table
     contained in the 2007 Form 10-K, actual bonus amounts for the named
     executive officers ranged from approximately 75% of base salary to 120% of
     base salary, with differences in relative amounts, as discussed above,
     resulting from an executive's relative contribution to the success of the
     Company for 2007.


<PAGE>

Securities and Exchange Commission
December 23, 2008
Page 3

     With respect to confidential treatment and the possibility of competitive
     harm, even if any one performance target were deemed to be material, we
     continue to believe that the disclosure of many these targets would allow
     the Company's competitors to discern the strategic direction, internal
     forecasts and key business objectives for both current year and future
     years. More specifically, because many of the performance targets discussed
     above relate to specific business lines of the Company and geographical
     operational results, we believe disclosure of such targets would provide
     our competitors with a roadmap to our strategic plans and operating
     objectives, and as such, disclosure of such information would result in
     substantial competitive harm to the Company. The Company, therefore,
     believes that such information constitutes "commercial and financial
     information obtained from a person and privileged or confidential" under
     the provisions of Section (b)(4) of Rule 80 of the Freedom of Information
     Act and may be excluded under Instruction 4 to Item 402(b).

2.   In future filings, please provide a more detailed discussion of how actual
     bonus awards and equity awards for each named executive officer were
     determined for your most recently completed fiscal year. Please compare
     actual performance during the year against the relevant targets. Also
     discuss the significance of individual assessments and any other
     qualitative factors. Tabular disclosure may be helpful. If there are
     material differences in bonus or equity awards to different named executive
     officers, your disclosure should explain why.

     As requested, in future filings the Company will provide a more detailed
     discussion of the Compensation Committee's determination process similar to
     the discussion provided above with respect to the 2007 bonus determination
     (modified to reflect any differences in the 2008 determination process).
     However, as indicated above, given the numerous financial and operational
     targets that are part of the Compensation Committee's discretionary
     determination process, the Company does not expect to include any detailed
     discussion of the specific target amounts; such targets do not reflect the
     Company's overall decision-making process and are immaterial to an
     understanding of executive compensation at the Company. The Company will
     also include a discussion of any material differences in bonus or equity
     awards among named executive officers, to the extent applicable.

Potential Payments upon Termination or Change in Control, page 20 of Proxy
Statement
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3.   In future filings, please quantify the value of the three years of medical
     benefits and potential gross-up payment to Mr. Silberman. Refer to
     Regulation S-K Item 402(j), Instructions 1 and 2. If you disagree that you
     are required to provide this disclosure, please explain to us the reasons
     why.

     As requested, in future filings we will disclose the value of the three
     years of medical benefits and potential gross-up payments to Mr. Silberman
     in connection with a termination of his employment.

4.   We note that you cross-reference your Outstanding Equity Awards tables for
     disclosure of the value that would be realized upon vesting due to a change
     in control. In future


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Securities and Exchange Commission
December 23, 2008
Page 4

     filings, please provide footnote disclosure to the tables so that the value
     that would have been realized assuming a change in control at year-end is
     clearly disclosed. Also, define "change in control" for these purposes.

     As requested, in future filings we will add footnotes in our Outstanding
     Equity Awards tables disclosing the value that would have been realized
     assuming a change in control at year-end. We will also provide in this
     section a definition of "change in control" for these purposes.

     Pursuant to your comment letter, on behalf of Strayer, we hereby
     acknowledge that:

     o    Strayer is responsible for the adequacy and accuracy of the disclosure
          in its 2007 Form 10-K;

     o    Staff comments or changes to disclosure in response to Staff comments
          do not foreclose the Commission from taking any action with respect to
          Strayer's 2007 Form 10-K; and

     o    Strayer may not assert Staff comments as a defense in any proceeding
          initiated by the Commission or any person under the Federal securities
          laws of the United States.

     Should any member of the Staff have any questions or comments concerning
this letter, please do not hesitate to call me at (212) 728-8592.

Very truly yours,

/s/ Jeffrey S. Hochman

Jeffrey S. Hochman

cc:  John Harrington
     Paul Fischer
     Robert S. Silberman
     Mark C. Brown
     Gregory Ferenbach

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