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corresp

June 8, 2011

Wilson K. Lee

Staff Accountant

Division of Corporation Finance

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

    Re:

    Ashford Hospitality Trust

Form 10-K for the year ended 12/31/2010 Filed on 3/4/2011

File No. 001-31775

Dear Mr. Lee:

     Ashford Hospitality Trust, Inc. (the “Company” or “we”) has received the staff’s comment
letter dated June 3, 2011 with respect to the report referenced above. We respectively submit the
responses below to your comment letter. To facilitate your review, the comments of the staff have
been set forth in italics and are followed by our responses.

FORM 10-K FOR THE YEAR ENDED DECEMBER 31, 2010

Item 2. Properties, page 31

    1.

    In future periodic filings please include in your hotel portfolio information details
regarding the hotel property type(s), such as, full service, limited service or extended stay.

     We confirm that in future periodic filings we will include our hotel portfolio information
that provides details regarding the hotel property types.

Liquidity and Capital Resources, page 40

    2.

    In future periodic filings, with respect to your ATM program and to the extent shares are
sold in the reporting period, please disclose the amount of shares sold, average price and/or
gross proceeds, net proceeds or offering expenses/commissions, the use of proceeds for sales,
and amount remaining in the program in such reporting period.

     As of June 8, 2011, no shares have been sold under the ATM program. We confirm that in the
future if any shares are sold pursuant to the ATM program, we will include the disclosures noted in
your comment in our periodic filings.

Mr. Wilson K. Lee

June 8, 2011

Page 2

Financial Statements and Notes

Consolidated Statements of Operations, page 60

    3.

    We note that you have included dividends declared per common share on the face of your
Consolidated Statements of Income versus in the notes to your financial statements. Tell us
how your disclosure complies with the guidance in paragraph 260-10-45-5 of the FASB Accounting
Standards Codification.

     The guidance provided by Accounting Standards Codification paragraph 260-10-45-5 does not
require the disclosure of dividends per share on the face of the income statement. However, we
believe that disclosing dividends per share on the face of the income statement is pertinent and
informative to investors although the same disclosure has been included in Item 6 pursuant to
Regulation S-K, Item 301. In future filings, we will delete the disclosure of dividends per share
on the face of our Consolidated Statements of Operations.

     The Company acknowledges that:

    •

    the Company is responsible for the adequacy and accuracy of disclosures 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.

     We respectfully submit the foregoing for your consideration in response to your comment letter
dated June 3, 2011. If you have any further questions concerning this filing, please contact me at
(972) 778-9202.

    Sincerely,

/S/ DAVID J. KIMICHIK

David J. Kimichik

Chief Financial Officer

Ashford Hospitality Trust, Inc.

14185 Dallas Parkway, Suite 1100

Dallas, Texas 75254