0702020 Informal Interpretation

February 27, 2007

VIAE-MAIL and U.S, FIRST CLASS MAIL

MichaelB. Verne

PremergerNotification Office

Bureauof Competition

FederalTrade Commission

600 Pennsylvania Avenue, N.W.

Washington, D.C. 20580

Re: Acquisition of Exclusive Service Providers bya REIT

Dear Mr. Verne:

I am writing to confirm our discussion yesterdayregarding the following proposed transaction (the "Proposed Transaction):

Our client, a real estate investment trust (the"REIT"), is considering a transaction in which the REIT will acquireone-hundred percent of the outstanding voting securities of a corporation thatprovides the REIT business advisory services and of three corporations thatprovide the REIT property management services (collectively, the "ServiceCompanies"), The Service Companies currently provide services exclusivelyto the REIT.

This confirms your advice that the ProposedTransaction is exempt from the premerger notification requirements underthe Hart-Scott-Rodino Antitrust Improvements Act under the ordinarycourse of business exemption.

Pleaselet me know if this does not accurately summarize of our discussion or yourconclusion.