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VIA EDGAR and VIA FACSIMILE (202.772.9209)

May 29, 2008

    Kevin Woody

    Robert Telewicz

    Accounting Branch Chief

    Staff Accountant

    Division of Corporation Finance

    Division of Corporation Finance

    United States Securities & Exchange Commission

    United States Securities & Exchange Commission

    450 Fifth Street, N.W.

    450 Fifth Street, N.W.

    Washington, DC 20549

    Washington, DC 20549

    Re:

    HEALTH CARE REIT, INC.:

    Form 10-K for the year ended December 31, 2007

    SEC File No. 1-08923

Dear Messrs. Woody and Telewicz:

The purpose of this letter is to respond to the comments raised in your letter addressed to Health
Care REIT, Inc. (the “Company”) dated April 29, 2008. Our response to each comment is set forth
below.

Form 10-K for the year ended December 31, 2007

Item 7. Management’s Discussion and Analysis of Financial Condition and Results of Operations

Key Performance Indicators, Trends and Uncertainties

Portfolio Update, page 44

    1.

    It appears that your ratios of CBMF and CAMF may be based on either a numerator or
denominator that is a non-GAAP measure. Explain to us how these ratios comply with all the
disclosure requirements of Item 10(e). In addition, please provide us with a calculation of
CBMF and CAMF and a reconciliation of the numerators and denominators used in both
calculations to the most directly comparable GAAP financial measure.

RESPONSE:

Neither CBMF nor CAMF are non-GAAP financial measures of the Company within the meaning of Item
10(e) because the adjusted earnings that are used in these ratios are adjustments to earnings

May 29, 2008

Page 2

of our lessees and borrowers, not earnings of the Company, and are not calculated from GAAP
measures presented in our financial statements. Our Quarterly Report on Form 10-Q for the
quarterly period ended March 31, 2008 (page 22) clarifies that these ratios relate to earnings of
our customers, and we intend to include this clarification in future filings with the Commission.

Non-GAAP Financial Measures, page 58

    2.

    Explain to us how you have met all of the disclosure requirements of Item 10(e) of Regulation
S-K and question 8 of the Frequently Asked Questions Regarding the Use of Non-GAAP Financial
Measures with respect to your measure of Funds Available for Distribution. In your response
explain to us how a measure entitled “Funds Available for Distribution,” and which appears to
be adjusted for certain cash items, can be considered a performance measure rather than a
liquidity measure.

RESPONSE:

The non-GAAP measure that we refer to as funds available for distribution is used by us to
facilitate internal and external comparisons to our operating results, in making operating
decisions and in the evaluation of management, as explained on pages 43 and 58 of our Annual Report
on Form 10-K for the year ended December 31, 2007. We believe that this non-GAAP financial measure
is also widely used by investors, equity and debt analysts and rating agencies in the valuation,
comparison, rating and investment recommendation of REITs. For these reasons, we have included
this non-GAAP financial measure in past Form 10-K and Form 10-Q filings. We have decided to cease
use of this non-GAAP financial measure in these filings in the future.

    3.

    We note that you present the measures EBITDA — adjusted. Explain to us how you have met all
the requirements of Item 10(e) of Regulation S-K and questions 8 and 10 of the Frequently
Asked Questions Regarding the use of Non-GAAP Financial Measures with respect to this measure.

RESPONSE:

As noted in the Company’s discussion of EBITDA on page 60 of our Annual Report on Form 10-K for the
year ended December 31, 2007, Adjusted EBITDA represents EBITDA as adjusted for certain items
pursuant to a covenant provision of the Company’s unsecured line of credit arrangement. Upon
review of question 10 of Frequently Asked Questions Regarding the Use of Non-GAAP Financial
Measures, we noted that the existing MD&A discussion may not adequately address the three
discussion points outlined therein. As such, in future filings, the Company will expand its MD&A
disclosure related to Adjusted EBITDA to include a discussion of the following:

May 29, 2008

Page 3

    •

    The materiality of the unsecured line of credit arrangement and the relevant covenant;

    •

    The limit required for compliance with the covenant; and

    •

    The actual or reasonably likely effects of compliance or non-compliance with the
relevant covenant on the Company’s financial condition and liquidity.

Item 8. Financial Statements and Supplementary Data

Notes to Consolidated Financial Statements

1. Accounting Policies and Related Matters

Real Property Owned, page 70

    4.

    We note that you base your allocation of acquisition costs to tangible assets on the report
of independent real estate appraisal firms. As these independent firms appear to be experts,
please revise your filing to name the firms and to provide the appropriate consents.

RESPONSE:

We understand that the referenced item could be misinterpreted to imply that the Company relies
solely on the work of appraisal firms for the allocation of certain acquisition costs. We wish to
inform you that this is not the case. To avoid such possible misinterpretation in the future, we
will remove such references to independent appraisal firms from future filings.

2. Business Combinations, page 73

    5.

    Explain to us how you have met the disclosure requirements of paragraph 54 of SFAS 141 with
respect to the Windrose Medical Properties Trust merger and the Rendina/Paramount Acquisition.

RESPONSE:

Paragraph 54 of SFAS 141 requires that the notes to the financial statements include certain
supplemental information on a pro forma basis for the period in which a material business
combination occurs. First, regarding the Windrose Medical Properties Trust merger, this material
business combination occurred on December 20, 2006. We refer you to Note 2 to the financial
statements included in the Company’s Annual Report on Form 10-K/A for the year ended December 31,
2006 for the required pro forma disclosures. Second, regarding the Rendina/Paramount acquisition,
the Company believes that this transaction was not a material business combination and, therefore,
that the pro forma disclosures were not required. Notwithstanding the immateriality of the
transaction, the Company desired to provide limited

May 29, 2008

Page 4

disclosure about the transaction and elected to include this information in Note 2 to the financial
statements included in its Annual Report on Form 10-K for the year ended December 31, 2007.

* * *

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

    •

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

    •

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

    •

    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.

We hope you will find the foregoing responsive to your comments. If you have any questions
regarding any of the above, please do not hesitate to call Paul D. Nungester, Vice President and
Controller of the Company, or the undersigned, Scott A. Estes, at 419-247-2800. Thank you very
much.

    Very truly yours

    HEALTH CARE REIT, INC.

    By:

    /s/ Scott A. Estes

    Scott A. Estes

    Its:

    Senior Vice President and

    Chief Financial Officer