[SHEFSKY & FROELICH LTD. LETTERHEAD]
|
|
|
|
| MICHAEL J. CHOATE |
|
| Direct: 312-836-4066 |
|
| Facsimile: 312-275-7554 |
|
| E-mail: mchoate@shefskylaw.com |
|
|
|
|
|
|
|
| IN REFERENCE TO: |
|
| 026829-014 |
August 22, 2008
VIA FEDERAL EXPRESS
Mr. Michael McTiernan
Special Counsel
United States Securities and Exchange Commission
Division of Corporate Finance
Mail Stop 4561
100 F Street, NE
Washington, D.C. 20549
| Re: | Inland American Real Estate Trust, Inc. |
|
| Post-Effective Amendment to Form S-11 |
|
| Registration No. 333-139504 |
|
| Filed on July 21, 2008 |
Dear Mr. McTiernan:
On behalf of our client, Inland American Real Estate Trust, Inc. (the “Company”), please find enclosed a complete copy of Pre-Effective Amendment No. 1 to Post-Effective Amendment No. 6 to the Company’s registration statement on Form S-11 (the “Amendment”), which includes Supplement No. 29 to its prospectus dated August 1, 2008 (the “Supplement”), as filed with the Securities and Exchange Commission via EDGAR on August 22, 2008. The Amendment includes revisions in response to the comment letter from the staff of the Division of Corporation Finance of the Securities and Exchange Commission (the “Staff”) to Mr. Robert Baum, dated July 22, 2008. This letter provides responses to the Staff’s comment letter, and the headings and paragraph numbers below correspond to the headings and paragraph numbers in that letter. For your convenience we have reproduced the Staff’s comments in this letter and included our response directly below each comment.
Supplement
1. Please include a section describing the current status of your offering, including the amount of proceeds raised to date, the amount of shares remaining to be offered and the termination date of the offering.
Mr. Michael McTiernan
August 22, 2008
Page 2
RESPONSE:
The Company has revised the section of its Supplement captioned “Summary Overview” to include a subsection captioned “Status of the Offering,” in which it discloses the current status of its offering, including the amount of proceeds raised to date, the amount of shares remaining for sale under the primary offering and the distribution reinvestment plan and the termination date of the offering. The enclosed copy of the Supplement, marked against supplement no. 26 included as part of the post-effective amendment filed on July 21, 2008 (referred to herein as the “Original Filing”), reflects these changes.
2. For each portfolio segment, please disclose your average rents.
RESPONSE:
The Company has revised the section of its Supplement captioned “Summary Overview” to include a subsection captioned “Average Rents,” in which it discloses the average base rent per square foot for each of its five property segments as of June 30, 2008. The enclosed copy of the Supplement, marked against the Original Filing, reflects these changes.
3. Please provide graphic or tabular illustration of the diversification of your portfolio by property type and geography.
RESPONSE:
The Company has revised the section of its Supplement captioned “Summary Overview — Property Overview” to provide graphic illustrations of the diversification of its property portfolio by property type and by geography as of June 30, 2008. The enclosed copy of the Supplement, marked against the Original Filing, reflects these changes.
4. Please disclose the percentage of your developments that are pre-leased.
RESPONSE:
The Company has revised the section of its Supplement captioned “Summary Overview — Developments” to disclose the percentage of each property that was pre-leased as of June 30, 2008. The enclosed copy of the Supplement, marked against the Original Filing, reflects these changes.
5. Please update your disclosure regarding recent acquisition activity to the date of the supplement. In addition, please include disclosure regarding occupancy, average rents and yields with respect to your recent acquisitions.
Mr. Michael McTiernan
August 22, 2008
Page 3
RESPONSE:
The Company has revised the section of its Supplement captioned “Summary Overview — Recent Acquisitions” to update its disclosure regarding recent acquisition activity through June 30, 2008, and to include information regarding the occupancy rate and effective annual rental per square foot for each recently acquired property. The Company also has included a discussion regarding the average yield for these recently acquired properties. The enclosed copy of the Supplement, marked against the Original Filing, reflects these changes.
6. We note your revenues and expenses tables which appear to present the build up to net operating income. Please break this information out by property segment and please present for the three months ended March 31, 2008 and the year ended December 31, 2007.
RESPONSE:
The Company has revised the section of its Supplement captioned “Summary Overview” to include a subsection captioned “Property Income and Expenses by Property Type,” which includes tables that provide operating information for each of the Company’s five property segments for the six months ended June 30, 2008 and the year ended December 31, 2007. The enclosed copy of the Supplement, marked against the Original Filing, reflects these changes.
Please contact us if there is any other information you need for your review of the Amendment. Kind regards.
| Very truly yours, |
| ||
|
|
| ||
| SHEFSKY & FROELICH LTD. | |||
|
|
| ||
| /s/ Michael J. Choate |
| ||
| Michael J. Choate |
| ||
|
|
| ||
cc: | Lori J. Foust |
| ||
|
|
| ||
