MORRIS, MANNING & MARTIN, L.L.P.
                          1600 ATLANTA FINANCIAL CENTER
                            3343 PEACHTREE ROAD, N.E.
                             ATLANTA, GEORGIA 30326



                                                                  (404) 504-7613
                                November 30, 2004

VIA EDGAR
Securities and Exchange Commission
Main Filing Desk
Stop 1-4
450 5th Street, N.W.
Washington, D.C.  20549-1004

RE:     Behringer Harvard Opportunity REIT I, Inc. - Registration Statement
        on Form S-11 Relating to Proposed Sale of Up to 44,000,000 Shares
        of Common Stock

Ladies and Gentlemen:

        Our client, Behringer Harvard Opportunity REIT I, Inc. (the "Company"),
is filing herewith a Registration Statement on Form S-11 with respect to the
proposed offer and sale of up to a total of 44,000,000 shares of common stock,
$0.0001 par value per share, of the Company.

        Funds in the amount of $55,748, representing the registration fee
payable to the Commission, were transmitted to the Commission by wire transfer
on November 23, 2004 (Reference Number 041124032250). Receipt of these funds was
confirmed with the Staff prior to the filing hereof.

        The Company is a newly incorporated Maryland corporation that intends to
qualify as a real estate investment trust under U.S. federal tax law. The
Company was incorporated at the direction of its sponsor, the Behringer Harvard
Funds (the "Sponsor"). The Sponsor also is the sponsor of various other real
estate programs, including Behringer Harvard REIT I, Inc. and Behringer Harvard
Short-Term Opportunity Fund I LP, each of which is offering securities pursuant
to a registration statement on Form S-11 previously filed with, and reviewed and
declared effective by, the Commission. We note that the Company's registration
statement is based upon the registration statements of Behringer Harvard REIT I,
Inc. and Behringer Harvard Short-Term Opportunity Fund I LP (in each case, as
revised to reflect changes made in response to Staff comments), except that, to
the extent the investment programs offered by the entities differ in their
terms, we have revised the disclosure accordingly. We hope that you will take
this into consideration when determining the level of the Staff's review, if
any, of the Company's registration statement.

        Please do not hesitate to contact me at the telephone number above
regarding the enclosed materials. In my absence, you may contact Rosemarie
Thurston at (404) 504-7635 or James Sinnott at (404) 504-7637. My facsimile
number is (404) 365-9532.

                                  Sincerely,


                                  /s/David M. Calhoun
                                  David M. Calhoun