January 18, 2008


Mail Stop 04-09

David Lichtenstein
c/o The Lightstone Group
326 Third Street
Lakewood, New Jersey 08701

	RE:	Lightstone Value Plus Real Estate Investment Trust, Inc.
      Post-Effective Amendment to
      Registration Statement on Form S-11
      File No. 333-117367
      Filed on January 15, 2008

Dear Mr. Lichtenstein:

      This is to advise you that we have conducted only a limited
review of your registration statement.  Based on that limited
review,
we have the following comments.

1. Please revise the use of proceeds table on pages 6 and 64 such
that "amount available for investment" reflects the gross offering
proceeds minus the offering expenses.  In addition, please revise
the
latter half of the table to reflect the amount actually available
for
investment in properties after deduction of acquisition fees,
expenses and working capital reserves.

2. Please provide a summary of your current portfolio in the
summary
section.

3. Please update your occupancy, average rent and, with respect to
your retail and office properties, lease expiration information to
the nine months ended September 30, 2007 or a more recent date.
In
addition, please also include such data for 2006 to the extent you
owned the property prior to December 31, 2006.

*  *  *  *

      As appropriate, please amend your filing in response to
these
comments.  Please understand that we may have additional comments
after reviewing your amendment and responses to our comments.

      We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings reviewed by the staff to
be
certain that they have provided all information investors require
for
an informed decision.  Since the company and its management are in
possession of all facts relating to a company`s disclosure, they
are
responsible for the accuracy and adequacy of the disclosures they
have made.

	Before the amended registration statement is declared
effective
pursuant to Section 8 of the Securities Act, the company should
provide us a letter, acknowledging that:

?	should the Commission or the staff, acting pursuant to
delegated
authority, declare the filing effective, it does not foreclose the
Commission from taking any action with respect to the filing;

?	the action of the Commission or the staff, acting pursuant to
delegated authority, in declaring the filing effective, does not
relieve the company from its full responsibility for the adequacy
and
accuracy of the disclosure in the filing; and

?	the company may not assert staff comments and the declaration
of
effectiveness as a defense in any proceeding initiated by the
Commission or any person under the federal securities laws of the
United States.

      In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in connection with our review of
your
filing or in response to our comments on your filing.

	Please contact me at (202) 551-3852 with any other questions.

						Sincerely,


						Michael McTiernan
						Special Counsel

cc:  	Peter Fass (via facsimile)
	Proskauer Rose LLP


David Lichtenstein
Lightstone Value Plus Real Estate Investment Trust, Inc.
January 18, 2008
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