One James Center 901 East Cary Street Richmond, VA 23219-4030 Phone: 804.775.1000 Fax: 804.775.1061 www.mcguirewoods.com
Martin B. Richards Direct: 804.775.1029 |
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April 10, 2014
VIA EDGAR
U.S. Securities and Exchange Commission
Division of Corporation Finance
100 F. Street, N.E.
Washington, D.C. 20549
Apple REIT Ten, Inc.
Registration Statement on Form S-11
Filed January 17, 2014
File No. 333-193404
Ladies and Gentlemen:
We are responding on behalf of our client, Apple REIT Ten, Inc. (the “Company”), to the oral comment we received from the staff telephonically on April 8, 2014. We thank you and other members of the staff for the prompt and helpful processing of the Company’s filing, and for reviewing this response letter.
In response to the oral comment received, in the event the Company extends its best efforts offering beyond July 2014, the Company hereby undertakes to update, in its next post-effective amendment, the prior performance tables contained in the prospectus in accordance with the Division’s Disclosure Guidance Topic 6.
The Company understands that it is responsible for the accuracy and adequacy of the disclosure in its filings and to ensure that it will have provided all information investors require for an informed decision.
We thank the staff very much for its prompt attention to the Company’s filing and for its ongoing assistance in processing this filing.
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April 10, 2014
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Any questions concerning this letter may be directed to the undersigned at (804) 775-1029 or to David F. Kurzawa at (804) 775-7471.
Very truly yours,
/s/Martin B. Richards
| cc: | Glade M. Knight |
| David S. McKenney | |
| David P. Buckley | |
| Bryan F. Peery |