SEC Company Response from ARDEN REALTY INC (CIK 0001013794) — Jan 14, 2005
ARDEN REALTY INC (CIK 0001013794)
Date: Jan. 14, 2005 · CIK: 0001013794 · Accession: 0000950129-05-000384
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CORRESP
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corresp
[Letterhead of Latham & Watkins LLP]
January 14, 2005
BY EDGAR TRANSMISSION
Securities and Exchange Commission
Judiciary Plaza
450 Fifth Street, N.W.
Washington, D.C. 20549
Re:
Arden Realty, Inc.
Arden Realty Limited Partnership
Registration Statement on Form S-3
Ladies and Gentlemen:
On behalf of Arden Realty, Inc., a Maryland corporation (the “Company”) and Arden Realty
Limited Partnership, a Maryland limited partnership (the “Partnership,” and together with the
Company, the “Registrants”), we enclose for filing pursuant to the Securities Act of 1933, as
amended, the Registrants’ Registration Statement on Form S-3, together with exhibits, with respect
to the Partnership’s registration of up to $500,000,000 aggregate offering price of debt securities
and the Company’s registration of up to $257,187,398 aggregate offering price of shares of common
stock and preferred stock and guarantees of the debt securities.
The Registrants have transmitted $76,621 via wire transfer to the Securities and Exchange
Commission’s account at the Mellon Bank in payment of the registration fee.
Please note that with respect to Exhibit 8.1 to the Registration Statement, we have filed a
form of opinion of Latham & Watkins LLP regarding tax matters. The final, executed opinion will be
filed by amendment. Please contact the undersigned at (714) 755-8197 if you have any questions or
comments regarding the enclosed.
Very truly yours,
/s/ MICHAEL A. TRESKA
Michael A. Treska
of LATHAM & WATKINS LLP
Enclosure
cc:
Arden Realty, Inc.
Arden Realty Limited Partnership