UNITED STATES
                                SECURITIES AND EXCHANGE COMMISSION
                                             WASHINGTON, D.C. 20549


     DIVISION OF
CORPORATION FINANCE


                                                              April 19, 2019

  Via E-Mail

  Eleazer Klein
  Schulte Roth & Zabel LLP
  919 Third Avenue
  New York, NY 10022

          Re:     Mack-Cali Realty Corporation
                  PREC14A filed on April 16, 2019
                  DFAN14A filed April 16, 2019
                  Filed by Bow Street LLC et al.
                  File No. 1-13274

  Dear Mr. Klein:

          The staff in the Office of Mergers and Acquisitions in the Division
of Corporation
  Finance has conducted a limited review of the filing listed above and have
the following
  comments. In some of our comments, we may ask you to provide us with
information so we may
  better understand your disclosure.

         Please respond to this letter by revising your proxy statement, by
providing the requested
  information, or by advising us when you will provide the requested response.
If you do not
  believe our comments apply to your facts and circumstances or do not believe
an amendment is
  appropriate, please tell us why in your response.

         After reviewing any amendment to your filing and the information you
provide in
  response to these comments, we may have additional comments. All defined
terms used here
  have the same meaning as in your proxy statement, unless otherwise indicated.

  Preliminary Proxy Statement filed on April 16, 2019

      1. Throughout the proxy statement where you provide details about your
proposed
         transaction with Mack-Cali, clarify that this proxy statement relates
only to the director
         election contest (and other routine matters) and is not a vote on your
Transaction
         Proposal. In addition, clarify that even if elected, your nominees
will constitute a
         minority of the Board and would not be able to cause the sale of the
Company assets you
         propose to purchase without the support of other directors.

      2. For the net asset values you attribute to components of your
Transaction Proposal (such
         as the new ApartmentCo REIT you would create), provide support as to
how these
 Eleazer Klein, Esq.
Schulte Roth & Zabel LLP
April 19, 2019
Page 2

      figures were derived and from what specific sources and valuations.

   3. Rule 14a-9 prohibits false or misleading (including by omission)
statement in proxy
      materials. Note (a) to Rule 14a-9 states that "[p]redictions as to
specific market values"
      may be misleading, in particular where there is inadequate factual basis
to support such
      statements. Revise to explain the basis for and to support the following
prediction:
      "Bow Street believes that the Transaction Proposal would deliver
immediate value of up
      to $27-$29 per share of Common Stock, representing a significant premium
to its current
      trading price and its long-term trading levels." To the extent that an
adequate basis
      cannot be provided, this statement should be deleted.

   4. Avoid statements that ascribe intent to the Mack-Cali Board.
Characterizations of the
      Board's actions as "uninformed" or "perfunctory," or its actions as
evidencing a "lack of
      commitment to shareholder values" should be modified in a manner that
avoids implying
      you know the motivations behind the Board's actions or lack of action.
Similarly,
      statements about the lack of any meaningful inquiry by the Board
regarding your
      Transaction Proposal, or its unwillingness to consider any proposals not
generated
      internally (which statement appears in the DFAN14A materials filed April
16, 2019)
      should be avoided in future filings, since you are not in a position to
know what the
      Board did or did not do or what it has or will consider.

   5. We note the following statement in your proxy statement: "Over the years,
Bow Street
      has invested heavily in REITS, including publicly-announced offers to
privatize publicly-
      traded REITs." Please provide support for this statement by providing (by
footnote or
      otherwise) clarification about the timeframe referenced, and by providing
examples of
      such investments.

   6. Where you first use the acronym DWREI, explain what it stands for and
describe your
      relationship with that entity (we note that it jointly submitted the
Transaction Proposal
      with Bow Street to acquire assets of Mack-Cali). In addition, if there
are arrangements,
      understandings or relationships between you and DWREI going forward,
please revise to
      describe.

   7. See our last comment above. Is DWREI a participant in this contest under
the definition
      set forth in Instruction 3 to Items 4 and 5 of Schedule 14A? Explain in
your response
      letter. If you determine they are a participant, revise the proxy
statement to include the
      information required by Schedule 14A, or indicate whether that
information already
      appears in your filing.
 Eleazer Klein, Esq.
Schulte Roth & Zabel LLP
April 19, 2019
Page 3



       We remind you that the filing persons are responsible for the accuracy
and adequacy of
their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.

       Please direct any questions to me at (202) 551-3263.


                                                            Sincerely,


                                                            /s/ Christina Chalk


                                                            Christina Chalk
                                                            Senior Special
Counsel
                                                            Office of Mergers
and Acquisitions