BEHRINGER HARVARD REIT I, INC.
July 23, 2008
Via Edgar and Federal Express
Ms. Cicely LaMothe
Division of Corporation Finance
Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Re: |
| Behringer Harvard REIT I, Inc. |
|
| Form 10-K for the year ended 12/31/2007 |
|
| Filed on 3/31/2008 |
|
| File No. 000-51293 |
Dear Ms. LaMothe:
On behalf of Behringer Harvard REIT I, Inc. (the “Company”), I am writing in response to the comment of the Staff with respect to the financial statements and related disclosures in the Company’s Form 10-K for the fiscal year ended December 31, 2007, as set forth in the Commission’s letter dated July 17, 2008. The headings and paragraph number below correspond to the headings and paragraph number of the Commission’s letter. In addition, for your convenience we have reproduced your comment in this letter and included our response directly below the comment.
Financial Statements and Notes
Note 12 – Stockholders’ Equity
Capitalization, page F-19
1. We have reviewed your response to comment 2 and note the board issued the convertible stock at an agreed upon nominal price. However, it is not clear whether this agreed upon value represents fair value under generally accepted accounting principles. Please advise us, and to the extent the difference between fair value and the nominal value assigned is not material disclose that fact.
RESPONSE: At the date of issuance of the shares of convertible stock, management determined the fair value under generally accepted accounting principles was less than the nominal value paid for the shares; therefore, the difference is not material. The Company will disclose that fact in its future filings.
Please contact me if you have any questions regarding the foregoing.
| Very truly yours, |
|
|
| BEHRINGER HARVARD REIT I, INC. |
|
|
| /s/ Gary S. Bresky |
|
|
| Gary S. Bresky |
| Chief Financial Officer |
cc: | Gerald J. Reihsen, III |
| 15601 Dallas Parkway, Suite 600 | |
| Telisa Webb Schelin |
| Addison, Texas 75001-6026 | |
| Michael J. Choate |
| www.behringerharvard.com | |
|
| Main: | 866.655.3600 (toll-free) | |
