[Letterhead of Clifford Chance US LLP]
December 31, 2008
VIA EDGAR
Ms. Karen Garnett
Asst. Director
United States Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, D.C. 20549-0405
| Re: | CB Richard Ellis Realty Trust |
| Pre-Effective Amendment No. 1 to Post-Effective Amendment No. 9 to Registration Statement on Form S-11, filed on December 23, 2008 (the “Post-Effective Amendment”) |
| Registration No. 333-127405 |
Dear Ms. Garnett:
As counsel to CB Richard Ellis Realty Trust, a Maryland real estate investment trust (the “Company”), and in accordance with our conversations with you regarding the Company’s Post-Effective Amendment, we supplementally advise you that the Company will disclose estimated acquisition cap rate information for newly acquired unconsolidated properties in its future filings with the Securities and Exchange Commission. The Company will also disclose the estimated acquisition cap rate information for the AllPoints Midwest Bldg. 1 and 125 Enterprise Parkway unconsolidated properties in the Company’s next prospectus supplement that it is required to file in accordance with Rule 424.
If you have any questions, please contact the undersigned at 212-878-3268 or Jason D. Myers at 212-878-8324.
Very truly yours,
By: /s/ Kristina V. Fink
Kristina V. Fink
| cc: | Jack A. Cuneo |
| Jason D. Myers, Esq. |
