[Letterhead of Willkie Farr & Gallagher LLP]



April 23, 2004

Securities and Exchange Commission
Division of Corporate Finance
450 Fifth Street, N.W.

Washington, DC 20459

  RE: American Campus Communities, Inc. -- Registration Statement on Form S-11

Ladies and Gentlemen:

In accordance with the requirements of the Securities Act of 1933, as amended
(the "Act"), electronically transmitted herewith is a Registration Statement on
Form S-11, together with exhibits (the "Registration Statement"), with respect
to the initial public offering of shares of Common Stock of American Campus
Communities, Inc. (the "Company"). The signature pages and consents have been
manually executed prior to the time of this electronic filing and will be
retained by the Company for five years.

In accordance with Rule 13(c) of Regulation S-T promulgated under the Act, the
Company has sent by wire transfer to the Commission's lockbox depository the
amount of $32,091 in payment of the required registration fee.

We advise the staff of the Securities and Exchange Commission (the "Staff") that
copies of the prospectus contained in this Registration Statement will not be
made generally available to the public until after comments have been received
from the Staff and an amendment to the Registration Statement has been filed to
incorporate all information required by Section 10 of the Act (other than
information permitted to be omitted by Rule 430A). Accordingly, share and per
share data and all other required information relating to the offering will be
added to the Registration Statement by amendment.

Pursuant to Rule 461 promulgated under the Act, the Staff is hereby notified
that the Company and Citigroup Global Markets Inc. and Deutsche Bank Securities
Inc. (the "Managing Underwriters") desire to make oral requests to the Staff
requesting the acceleration of effectiveness of the Registration Statement. The
Company and the Managing Underwriters have indicated to the undersigned that
each of them is aware of their respective obligations under the Act.

Please contact the undersigned at (212) 728-8225 should you have any questions
or comments with regard to this matter.

Sincerely,

/s/ Yaacov M. Gross
- ------------------------
Yaacov M. Gross

cc: William C. Bayless, Jr.
    Paul Ingrassia
    Geoffrey Bedrosian
    Edward F. Petrosky