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CLIFFORD | | CLIFFORD CHANCE US LLP |
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CHANCE | | |
| | | 31 WEST 52ND STREET |
| | | NEW YORK NY 10019 |
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| | | TEL +1 212 878 8000 |
| | | FAX +1 212 878 8375 |
| | | www.cliffordchance.com |
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| TO | | Geoffrey M. Ossias | | COMPANY | | Securities and Exchange Commission |
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| FAX NO | | 202-772-9209
202-942-9544 | | PHONE NO | | 202-551-3404 | | |
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| FROM | | Elizabeth M. McCarroll | | DATE | | October 20, 2005 |
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| CC | | Andrew Epstein | | | | | | |
| | | Eric Graham | | | | | | |
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| SENDER PHONE | | +1 212 878 3437 | | PAGES (INCL COVER) | | 2 | | |
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Re: | | Cogdell Spencer Inc. | | |
| | | File No. 333-127396 | | |
In response to Comment number 14 from the letter dated October 20, 2005, attached for your review please find a copy of one of the investor information pages from our subscription packages. We do not feel it is appropriate to file this information with our registration statement as it is not meaningful to a potential investor and otherwise discloses private and confidential information regarding the investors in the existing entities. We would like to discuss this item, as well as Comment 10 tomorrow with you. We expect to refile an amendment tomorrow.
Regards,
Elizabeth McCarroll
FOR FAX TRANSMISSION PROBLEMS, CALL +1 212 878 8374 THIS FACSIMILE TRANSMISSION IS INTENDED SOLELY FOR THE USE OF THE PERSON OR ENTITY TO WHICH IT IS ADDRESSED AND MAY CONTAIN INFORMATION THAT IS PRIVILEGED, CONFIDENTIAL AND EXEMPT FROM DISCLOSURE UNDER APPLICABLE LAW. ANY REVIEW, DISSEMINATION, DISTRIBUTION, COPYING OR OTHER USE OF, OR THE TAKING OF ANY ACTION IN RELIANCE UPON, THIS TRANSMISSION OR ITS CONTENTS BY PERSONS OTHER THAN THE ADDRESSEE IS STRICTLY PROHIBITED. IF YOU HAVE RECEIVED THIS COMMUNICATION IN ERROR, OR ARE UNCERTAIN ABOUT ITS PROPER HANDLING, PLEASE CALL US IMMEDIATELY (COLLECT AT +1 212 878 8374) AND RETURN THE ORIGINAL TRANSMISSION TO US BY MAIL.
COGDELL INVESTORS (MALLARD), LLC
Contact:
Michael Matthews, AVP
4401 Barclay Downs Dr., Suite 300
Charlotte, NC 28262
(704) 940-2900
Cogdell Spencer Advisors Inc.
(704) 940-2900
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| | | Current | | | | | | | | |
| | | Ownership % in | | | | | | | | |
| | | Cogdell Investors | | | | | | | Number of | |
| Investor | | (Mallard), LLC | | | Cash Value | | | OP Units | |
| Charles M. Handy | | | 4.08 | % | | $ | 102,616 | | | | 5,583 | |
| Cogdell Spencer Advisors | | | 6.63 | % | | $ | 166,752 | | | | 9,072 | |
| Frank Spencer | | | 15.31 | % | | $ | 385,063 | | | | 20,948 | |
| James W. Cogdell | | | 66.33 | % | | $ | 1,668,271 | | | | 90,754 | |
| Matt Nurkin | | | 7.65 | % | | $ | 192,406 | | | | 10,467 | |
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| Total | | | 100 | % | | $ | 2,515,108 | | | | 136,824 | |
