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Mail Stop 4561
      November 30, 2005

Mr. William H. Schafer
Sr. Vice President and Chief Financial Officer
Developers Diversified Realty Corp.
3300 Enterprise Parkway
Beachwood, OH 44122

	Re:	Developers Diversified Realty Corp.
		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. 1-11690

Dear Mr. Schafer:

      We have reviewed your filings and have the following
comment.
We have limited our review to only the issue addressed below and
will
make no further review of your documents.  In our comment, we ask
you
to provide us with information so we may better understand your
disclosure.  After reviewing this information, we may raise
additional comments.

       Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.

Form 10-K for Fiscal Year Ended December 31, 2004

Item 2 Properties - Tenant Lease Expirations and Renewals, page 17

1. We reissue our previous comment by a letter sent on July 28,
2004.
We refer to the table on page 17.  It appears that you have
combined
wholly owned (consolidated) tenant lease information with tenant
leases held in joint ventures (equity method).  Since you derive
revenue from your wholly owned tenant leases differently than from
your tenant leases held in a joint venture they should be
presented
separately.  The information presented in future filings for joint
venture tenant leases should only

show your portion of the revenues.  We note in your response
letter
dated August 6, 2004 that you stated that the Company will draft
future filings accordingly.  Please tell us why you did not change
your presentation in accordance with our previous comment.

      Please respond to these comments within 10 business days or
tell us when you will provide us with a response.  Please file
your
response on Edgar.

      We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings to be certain that the
filings include all information required under the Securities
Exchange Act of 1934 and that they have provided all information
investors require for an informed investment decision.  Since the
company and its management are in possession of all facts relating
to
a company`s disclosure, they are responsible for the accuracy and
adequacy of the disclosures they have made.

	In connection with responding to our comments, please
provide,
in writing, a statement from the company acknowledging that

* the company is responsible for the adequacy and accuracy of the
disclosure in the filings;

* 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

* 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.

      In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in our review of your filings or
in
response to our comments on your filings.

      You may contact Thomas Flinn, Staff Accountant, at (202)
551-
3469 or the undersigned at (202) 551-3498 if you have questions.
      			Sincerely,

      Linda Van Doorn
Senior Assistant Chief Accountant

Mr. William H. Schafer
Developers Diversified Realty Corp.
November 30, 2005
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