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HEALTH CARE REIT, INC.   CORRESP

VIA EDGAR and VIA FACSIMILE (202.772.9209)

August 1, 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 comment in your letter to Health Care
REIT, Inc. (the “Company”) dated July 17, 2008 concerning the Company’s Form 10-K for the year
ended December 31, 2007. Your comment and our response 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 1. While question 10 of the Frequently
Asked Questions Regarding the Use of Non-GAAP Financial Measures allows for companies to
present an alternative EBITDA measure that would otherwise violate certain provisions of Item
10(e) of Regulation S-K as part of a discussion of a material agreement, we are unclear how it
allows for the omission of disclosures required by Item 10(e) of Regulation S-K or question 8
of the Frequently Asked Questions Regarding the Use of Non-GAAP Financial Measures. Explain to
us how you have arrived at this conclusion or revise your discussion in future filings to
include all the necessary disclosures.

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

August 1, 2008

Page 2

arrangement. As stated in our response dated May 29, 2008 to your comment letter dated April 29,
2008, 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 with the requirements of question 10 of the Frequently Asked Questions Regarding the Use
of Non-GAAP Financial Measures. In response to your July 17, 2008 comment letter, the Company will
further expand this discussion to include appropriate additional disclosure pursuant to the
guidance of question 8 of the Frequently Asked Questions Regarding the Use of Non-GAAP Financial
Measures, including a precautionary statement that Adjusted EBITDA is used by management solely to
determine our compliance with this line of credit covenant and is not being presented in the report
for use by investors for any other purpose. Further, this discussion will state that the
reconciliation table reflects the reconciliation of both EBITDA and Adjusted EBITDA to net income
as the most directly comparable U.S. GAAP measure. We believe that, as so expanded, this
disclosure in our future filings will satisfy all disclosure obligations under Item 10(e) of
Regulation S-K as well as all requirements under questions 8 and 10 of the Frequently Asked
Questions Regarding the Use of Non-GAAP Financial Measures.

We trust that the foregoing is responsive to your comment. 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