SecProbe.io

Mail Stop 4561       August 12, 2008          David Gladstone, Chief Executive Officer Gladstone Commercial Corporation 1521 Westbranch Drive Suite 200 Mclean, VA 22102
Re: Gladstone Commercial Corporation
 Form 10-K for the year ended December 31, 2007
Filed February 27, 2008 Schedule 14A Filed March 10, 2008
 File No. 001-33097

Dear Mr. Gladstone:
 We have reviewed your filing and have the following comments.  Where
indicated, we think you should re vise your document in response to these comments.  If
you disagree, we will consider your explanation as to why our comment is inapplicable or
a revision is unnecessary.  Please be as deta iled as necessary in your explanation.  In
some of our comments, we may ask you to provi de us with information so we may better
understand your disclosure.  After reviewing th is information, we may raise additional
comments.   Please understand that the purpose of our re view 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 any other aspect of our
review.  Feel free to call us at the telephone numbers listed at the end of this letter.
10-K Exhibit 31

1. In future filings please ensure that you provide the exact form of the certification
as set forth in Item 601(b)(31) of Regulat ion S-K.  For example, we note that in
paragraph (3), you refer to “quarterly report” or “annual report” instead of
“report.” We also note that in paragraph (4) you state: “for th e registrant and we
have” instead of “for the registrant and have.”  In addition, we note that in
paragraph 4(d) of Mr. Gladstone’s cer tification, you have not included a comma
after “materially affect.”

David Gladstone, Chief Executive Officer
Gladstone Commercial Corporation  August 12, 2008 Page 2
Schedule 14A

2. On page 24, we note that you have included disclosure regarding the amount
reimbursed to the administrator for Mr. Brill’s salary, bonus, and benefits.  In
future filings please include similar disc losure regarding reimbursements made to
your administrator for your othe r executive officer or advise.

**********

 As appropriate, please amend your filing and respond to these comments within
10 business days or tell us when you will provid e us with a response.  You may wish to
provide us with marked copies of the amendm ent to expedite our review.  Please furnish
a cover letter with your amendment that keys your responses to our comments and
provides any requested information.  Detailed co ver letters greatly faci litate our review.
Please understand that we may have addi tional comments after reviewing your
amendment and responses to our comments.    We urge all persons who are responsi ble for the accuracy an d adequacy of the
disclosure in the filing to be certain that the filing includes all in formation required under
the Securities Exchange Act of 1934 and th at they have provided all information
investors require for an informed invest ment decision.  Since the company and its
management are in possession of all facts re lating 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
filing;
‚ staff comments or changes to disclosure  in response to staff comments do not
foreclose the Commission from taking any action with respect to the filing; 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 advise d that the Division of Enfo rcement has access to all
information you provide to the staff of the Divi sion of Corporation Fi nance in our review
of your filing or in response to our comments on your filing.

David Gladstone, Chief Executive Officer
Gladstone Commercial Corporation  August 12, 2008 Page 3    Please direct any questions to Stacie Gorman at (202) 551-3585, or the undersigned at (202) 551-3233.
Sincerely,   Tom Kluck Legal Branch Chief