SKADDEN, ARPS, SLATE, MEAGHER & FLOMLLP 300 SOUTH GRAND AVENUE LOS ANGELES, CALIFORNIA 90071-3144 ________
| FIRM/AFFILIATE OFFICES ________ | |||
TEL: (213) 687-5000 FAX: (213) 687-5600 www.skadden.com
December 19, 2011 |
BOSTON CHICAGO HOUSTON NEW YORK PALO ALTO WASHINGTON, D.C. WILMINGTON ________
BEIJING BRUSSELS FRANKFURT HONG KONG LONDON MOSCOW MUNICH PARIS SÃO PAULO SHANGHAI SINGAPORE SYDNEY TOKYO |
VIA EDGAR
Adam F. Turk, Attorney-Advisor
Division of Corporation Finance
Securities and Exchange Commission
100 F. Street, N.E.
Washington, D.C. 20549
| Re: | Apartment Investment and Management Company AIMCO Properties, L.P. Registration Statement on Form S-4 | |
Filed July 28, 2011 File No.: 333-175846 |
Dear Mr. Turk:
Apartment Investment and Management Company (“Aimco”) and AIMCO Properties, L.P. (“Aimco OP”) are today filing an amendment to the Registration Statement (File No. 333-175846) on Form S-4 (the “CPF XVII Form S-4”) referenced above. The CPF XVII Form S-4 relates to the merger of Century Properties Fund XVII, LP.
We hereby confirm, on behalf of Aimco and Aimco OP, that the changes made to the CPF XVII Form S-4 are similar in nature to those that were previously made by Aimco and Aimco OP in the amendments to three Registration Statements on Form S-4 (File Nos. 333-175843, 333-175848 and 333-175853), filed with the Securities and Exchange Commission on November 15, 2011 (the “Prior Filings”). The changes made to the CPF XVII Form S-4 (including opinions filed as exhibits) respond to the Staff’s comments in the same manner as the Prior Filings.
* * * *
Mr. Adam F. Turk
Securities and Exchange Commission
December 19, 2011
Page 2
If you have any questions regarding the foregoing, please contact Jonathan Friedman at (213) 687-5396 or the undersigned at (213) 687-5567.
| Respectfully yours, |
/s/ Nicolai Schwarz-Gondek |
| Nicolai Schwarz-Gondek |
| cc: | John Bezzant, Executive Vice President | |
Apartment Investment and Management Company Trent Johnson, Vice President and Assistant General Counsel | ||
| Apartment Investment and Management Company |
