Histopathologic and immunohistochemical features of 3 cases of clear cell odontogenic carcinoma were studied. The tumors were composed of sheets or islands of clear cells separated by mature collageneous tissue. Basaloid cells were also seen in the tumors. Tumor cells showed positive reactions for epithelial membrane antigen and cytokeratin. More PCNA positive cells were seen in basaloid cells than in clear cells. Metastasis to regional lymph nodes was found in all 3 cases.