December 30, 2009
VIA EDGAR AND FACSIMILE
U.S. Securities and Exchange Commission
Attn: Jennifer Gowetski
Division of Corporation Finance
100 F Street, NE
Washington, DC 20549
Attn: Jennifer Gowetski
Division of Corporation Finance
100 F Street, NE
Washington, DC 20549
| RE: | Gladstone Commercial Corporation Form 10-K for the year ended December 31, 2008 Filed February 25, 2009 File No. 001-33097 |
Dear Ms. Gowetski:
We are in receipt of your December 18, 2009 letter (the “Correspondence”) to Gladstone Commercial Corporation (the “Company”) regarding the review of the above-referenced filing by the staff (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”). Our responses to each item raised in the Correspondence are provided below. For your convenience we have restated the comments provided by the Staff prior to each of our corresponding responses below.
Comment 1 — General:
We note that you appear to have used your old Exchange Act reporting number on the cover page of yourForm 10-K and your most recentForm 10-Q. In future filings, please use your current Exchange Act reporting number (001-33097) or advise.
Comment 1 — Response:
The Company will use the current Exchange Act reporting number (001-33097) in all future filings.
Comment 2 — Item 2. Properties, Page 22:
Please provide us a schedule of leases expiring in the next ten years, including the total area in square feet covered by such leases, the annual rental represented by such leases, and the percentage of gross annual rental represented by such leases on a portfolio basis. In addition, please tell us the geographic areas in which your properties are located on a portfolio basis. Confirm that you will provide similar disclosure in future filings.
Comment 2 — Response:
The Company has provided two additional tables below, which reflect the schedule of leases expiring in the next ten years and the geographical areas in which the Company’s properties are located. The Company will provide these tables in future filings with the Commission.
The following table summarizes the lease expirations by year for the Company’s properties for leases in place as of December 31, 2008:
| Year of Lease | Annualized Base | % of Annualized | ||||||||||||||
| Expiration | Square Feet | Number of Leases | Rental Revenue | Base Rent | ||||||||||||
| 2009 | 17,432 | 1 | $ | 211,183 | 0.5 | % | ||||||||||
| 2010 | 215,581 | 3 | 1,409,691 | 3.4 | % | |||||||||||
| 2011 | 30,268 | 1 | 536,324 | 1.3 | % | |||||||||||
| 2012 | 479,982 | 3 | 4,429,603 | 10.7 | % | |||||||||||
| 2013 | 438,422 | 6 | 4,670,909 | 11.2 | % | |||||||||||
| 2014 | 614,132 | 5 | 3,055,683 | 7.4 | % | |||||||||||
| 2015 | 879,444 | 8 | 6,494,747 | 15.6 | % | |||||||||||
| 2016 | 898,257 | 5 | 4,195,156 | 10.1 | % | |||||||||||
| 2017 | 102,200 | 1 | 922,927 | 2.2 | % | |||||||||||
| 2018 | 59,894 | 1 | 268,042 | 0.7 | % | |||||||||||
| 2019+ | 2,594,344 | 17 | 15,344,993 | 36.9 | % | |||||||||||
Total | 6,329,956 | 51 | $ | 41,539,258 | 100 | % | ||||||||||
The following table summarizes the geographic locations of the Company’s properties for leases in place as of December 31, 2008:
| Number of | Annualized Base | % of Annualized | ||||||||||||||
| State | Square Feet | Leases | Rental Revenue | Base Rent | ||||||||||||
| Ohio | 1,185,411 | 11 | $ | 7,366,813 | 17.7 | % | ||||||||||
| Minnesota | 547,800 | 3 | 5,211,470 | 12.5 | % | |||||||||||
| North Carolina | 695,876 | 6 | 3,777,316 | 9.1 | % | |||||||||||
| Pennsylvania | 623,375 | 4 | 3,008,444 | 7.2 | % | |||||||||||
| Texas | 188,178 | 4 | 2,353,410 | 5.7 | % | |||||||||||
| Michigan | 596,104 | 2 | 2,195,838 | 5.3 | % | |||||||||||
| Illinois | 164,131 | 2 | 2,186,019 | 5.3 | % | |||||||||||
| Massachusetts | 338,508 | 3 | 2,122,753 | 5.1 | % | |||||||||||
| All Other States | 1,990,573 | 16 | 13,317,195 | 32.1 | % | |||||||||||
Total | 6,329,956 | 51 | $ | 41,539,258 | 100 | % | ||||||||||
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The Company acknowledges that the adequacy and accuracy of the disclosure in the filing is the responsibility of the Company. The Company acknowledges that Staff comments or changes to disclosure in response to Staff comments do not foreclose the Commission from taking any action with respect to the filing. The Company also acknowledges that Staff comments may not be asserted as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
Please direct any further questions or comments concerning the filing or this response letter to the undersigned at (703) 287-5853.
| Sincerely, | ||||
| /s/ Danielle Jones | ||||
| Danielle Jones | ||||
| Chief Financial Officer | ||||
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