RegAlert2011-02-24
Added · Updated
SEC Division of Corporation Finance no-action letter: Inland American Real Estate Trust, Inc.
Inland American Real Estate Trust, Inc. proposes amending its share repurchase program to authorize repurchases solely upon the death of a beneficial owner, prioritizing requests based on the date of death rather than using a pro rata basis when funds are insufficient or the 5.0% annual limit is exceeded. The company requests that the Division of Corporation Finance agree not to recommend enforcement action under Rule 13e-4, asserting that this priority mechanism does not constitute a fraudulent, deceptive, or manipulative act. The proposed program limits quarterly repurchases to board-reserved operating funds, initially set at $5.0 million per quarter, and requires requests to be submitted within one calendar year of the owner's death.
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Shefsky• 111 E. Wacker Drive, Suite 2800 .TIl Chicago, Illinois 60601- 3713 Tel 312.527.4000 Fax 312.527.4011 & www.shefskylaw.com FroelIch Attorneys at Law KRISTIN A. KLACZEK Direct: 312-836-4092 Facsimile: 312-275-7585 E-mail: kklaczek@shefskylaw.com lr~ REFEJ'ENCr~ TO:
')26R29-29
February 24,2011
Via Federal Express and Electronic Mail
Ms. Michele Anderson, Chief
Mr. Daniel F. Duchovny, Special Counsel
Office ofMergers and Acquisitions
Division ofCorporation Finance
United States Securities and Exchange Commission 100 F Street, NE Washington, D.C. 20549 RE: Inland American Real Estate Trust, Inc.
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