SecProbe.io

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                            Shearman & Sterling LLP
                599 LEXINGTON AVENUE | NEW YORK | NY | 10022-6069
            WWW.SHEARMAN.COM | T +1.212.848.4000 | F +1.212.848.7179

(212) 848-8244

October 26, 2005

BY EDGAR AND FEDERAL EXPRESS

Mr. Jorge Bonilla
Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549

Re:      Alexander's, Inc.
         Form 10-K For the Fiscal Year Ended December 31, 2004
         Form 10-Q For the Quarterly Period Ended March 31, 2005
         Form 10-Q For the Quarterly Period Ended June 30, 2005
         File No. 1-06064

Dear Mr. Bonilla:

We refer to your letter dated October 20, 2005 regarding a comment on the
above-referenced filings of Alexander's, Inc. (the "Company"). We have set forth
below the Company's response to the comment in your letter. For your
convenience, we have included your comment in full before our response.

On behalf of the Company, we advise you as follows:

Form 10-Q for the Quarterly Period Ended June 30, 2005
------------------------------------------------------

Note 4 - 731 Lexington Avenue, page 8
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1.   You state that you are recognizing the sales of the condominium units using
     the percentage of completion method. We note on your balance sheet that you
     have significant receivables arising from the sale of condominiums. Please
     tell us how you considered these receivables in recognizing gain on these
     sales and how you applied the criteria outlined in paragraph 37 of SFAS 66.

         RESPONSE:

              The Company notes for the information of the Staff that the
         "receivables arising from the sale of condominiums" represent the
         difference between the sales price on the 22 units under contract for
         sale and the cash deposits received for those units. The Company has
         recognized

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         net gains on sale of condominiums in accordance with
         paragraph 37 of SFAS 66, which states that if individual units in
         condominiums projects are being sold separately, profit shall be
         recognized using the percentage of completion method if all of the
         following criteria are met:

(A)  Construction is beyond a preliminary stage
     o    At June 30, 2005, approximately 92% of the project had been completed
          and of the 105 condominium units, 77 had been sold and all proceeds
          collected and 22 were under binding sales contracts.

(B)  The buyer is committed to the extent of being unable to require a refund
     except for non delivery of the unit
     o    All deposits are non-refundable unless there is a material change in
          the condominium offering plan or in the event the Company is unable to
          deliver the units within a reasonable period of time, as defined.

(C)  Sufficient units have already been sold to assure that the entire property
     will not revert to rental property
     o    Of the 105 condominium units, 77 had been sold and closed and 22 were
          under binding sales contract at June 30, 2005.

(D)  Sales prices are collectible
     o    The Company had assessed the collectibility of the sales prices of the
          22 units under sales contract at June 30, 2005 in accordance with
          paragraph 4 of SFAS 66 and notes for the information of the Staff that
          the initial and continuing investments (non-refundable down payments
          made by purchasers) received on the 22 condominiums that had not
          closed as of June 30, 2005 were in excess of 25% of the purchase
          prices, thus giving the buyers a substantial incentive to complete the
          acquisition of the condominium units under binding sales contracts. In
          addition, these individuals were of high credit standing further
          mitigating any chance of default (these facts were similar for the 77
          units previously sold and, in each case, the entire purchase price was
          collected). The Company also notes for the information of the Staff
          that as of September 30, 2005, the sales of 21 of the 22 units had
          closed and the receivables relating to those 21 units have been
          collected in full.

(E)  Aggregate sale proceeds and costs can be reasonably estimated.
     o    At June 30, 2005, 92% of the project had been completed and
          substantially all of the remaining project costs have been contracted
          for.

                                      ****

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In connection with responding to your comment, the Company hereby acknowledges
that:

     o    the Company is responsible for the adequacy and accuracy of the
          disclosure in the filings;

     o    staff comments or changes to disclosure in response to staff comments
          do not foreclose the Commission from taking any action with respect to
          the filings; and

     o    the Company may not assert staff comments as a defense in any
          proceeding initiated by the Commission or any person under the federal
          securities laws of the United States.

If you have any additional comments or questions, please contact the undersigned
at (212) 848-8244 or Joseph Macnow, the Company's Chief Financial Officer, at
(201) 587-1000.

Very truly yours,

/s/ Danielle Carbone

Danielle Carbone

cc:  Joseph Macnow -- Alexander's, Inc.
     Alan Rice -- Alexander's, Inc.
     Thomas Flinn -- SEC

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