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HEALTH CARE REIT, INC.   Corresp

VIA EDGAR and VIA FACSIMILE (202.772.9209)

July 10, 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 additional comments in your letter to Health Care
REIT, Inc. (the “Company”) dated June 12, 2008 concerning the Company’s Form 10-K for the year
ended December 31, 2007. Your comments and our responses are 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

Non-GAAP Financial Measures, page 58

    1.

    We have considered your response to our prior comment 3. We are still unclear how you have
met all the 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 Adjusted EBITDA. Please tell us how you have complied with these disclosure requirements.

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. As stated
in our response dated May 29, 2008 to your prior comment letter, the Company will in future filings
expand its MD&A disclosure to include additional discussion of Adjusted EBITDA relating to and in
the context of this line of credit covenant so as to comply

July 10, 2008

Page 2

with the requirements of question 10 of
Frequently Asked Questions Regarding the Use of Non-GAAP Financial Measures. We believe that this additional information will satisfy the Company’s
disclosure obligations under Item 10(e) of Regulation S-K as long as Adjusted EBITDA is not
mentioned in any context other than the line of credit covenant requirement, as was the case with
the 2007 Form 10-K. Because Adjusted EBITDA has not been and will not be presented as a non-GAAP
performance measure, the requirements under question 8 of your Frequently Asked Questions Regarding
the Use of Non-GAAP Financial Measures should not apply. We believe any attempt to respond to
these requirements could confuse the explanation given in response to question 10 of the Frequently
Asked Questions.

Item 8. Financial Statements and Supplementary Data

Notes to Consolidated Financial Statements

2. Business Combinations, page 73

    2.

    We have reviewed your response to our prior comment 5 and note that you included the
disclosures required by paragraph 54 of SFAS 141 related to your acquisition of Windrose
Medical Properties Trust in your 2006 Form 10-K. We are unclear why these disclosures were
not also included in your 2007 Form 10-K. In future filings please ensure that you include
all appropriate financial statement disclosures for each year presented in your financial
statements.

RESPONSE:

We will comply with this request in our future filings.

* * *

We trust that the foregoing is 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