SEC Company Response from GLADSTONE COMMERCIAL CORP (GOOD, GOODN, GOODO) (CIK 0001234006) (GOOD) — Dec 30, 2009
GLADSTONE COMMERCIAL CORP (GOOD, GOODN, GOODO) (CIK 0001234006)
Date: Dec. 30, 2009 · CIK: 0001234006 · Accession: 0000950123-09-074093
AI Filing Summary & Sentiment
File numbers found in text: 001-33097
Letter
VIA EDGAR AND FACSIMILE Division of Corporation Finance Gladstone Commercial Corporation Form 10-K for the year ended December 31, 2008 Filed February 25, 2009 File No. 001-33097
RE:
Dear Ms. Gowetski:
We are in receipt of your December 18, 2009 letter (the “Correspondence”) to Gladstone Commercial Corporation (the “Company”) regarding the review of the above-referenced filing by the staff (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”). Our responses to each item raised in the Correspondence are provided below. For your convenience we have restated the comments provided by the Staff prior to each of our corresponding responses below.
Comment 1 — General:
We note that you appear to have used your old Exchange Act reporting number on the cover page of your Form 10-K and your most recent Form 10-Q. In future filings, please use your current Exchange Act reporting number (001-33097) or advise.
Comment 1 — Response:
The Company will use the current Exchange Act reporting number (001-33097) in all future filings.
Comment 2 — Item 2. Properties, Page 22:
Please provide us a schedule of leases expiring in the next ten years, including the total area in square feet covered by such leases, the annual rental represented by such leases, and the percentage of gross annual rental represented by such leases on a portfolio basis. In addition, please tell us the geographic areas in which your properties are located on a portfolio basis. Confirm that you will provide similar disclosure in future filings.
Comment 2 — Response:
The Company has provided two additional tables below, which reflect the schedule of leases expiring in the next ten years and the geographical areas in which the Company’s properties are located. The Company will provide these tables in future filings with the Commission.
The following table summarizes the lease expirations by year for the Company’s properties for leases in place as of December 31, 2008:
Year of Lease
Annualized Base
% of Annualized
Expiration
Square Feet
Number of Leases
Rental Revenue
Base Rent
17,432
$ 211,183
0.5 %
215,581
1,409,691
3.4 %
30,268
536,324
1.3 %
479,982
4,429,603
10.7 %
438,422
4,670,909
11.2 %
614,132
3,055,683
7.4 %
879,444
6,494,747
15.6 %
898,257
4,195,156
10.1 %
102,200
922,927
2.2 %
59,894
268,042
0.7 %
2019+
2,594,344
15,344,993
36.9 %
Total
6,329,956
$ 41,539,258
%
The following table summarizes the geographic locations of the Company’s properties for leases in place as of December 31, 2008:
Number of
Annualized Base
% of Annualized
State
Square Feet
Leases
Rental Revenue
Base Rent
Ohio
1,185,411
$ 7,366,813
17.7 %
Minnesota
547,800
5,211,470
12.5 %
North Carolina
695,876
3,777,316
9.1 %
Pennsylvania
623,375
3,008,444
7.2 %
Texas
188,178
2,353,410
5.7 %
Michigan
596,104
2,195,838
5.3 %
Illinois
164,131
2,186,019
5.3 %
Massachusetts
338,508
2,122,753
5.1 %
All Other States
1,990,573
13,317,195
32.1 %
Total
6,329,956
$ 41,539,258
%
The Company acknowledges that the adequacy and accuracy of the disclosure in the filing is the responsibility of the Company. The Company acknowledges that 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. The Company also acknowledges that Staff comments may not be asserted as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
Please direct any further questions or comments concerning the filing or this response letter to the undersigned at (703) 287-5853.
Sincerely,
/s/ Danielle Jones
Show Raw Text
CORRESP
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filename1.htm
corresp
December 30, 2009
VIA EDGAR AND FACSIMILE
U.S. Securities and Exchange Commission
Attn: Jennifer Gowetski
Division of Corporation Finance
100 F Street, NE
Washington, DC 20549
RE:
Gladstone Commercial Corporation Form 10-K for the year ended December 31, 2008
Filed February 25, 2009
File No. 001-33097
Dear Ms. Gowetski:
We are in receipt of your December 18, 2009 letter (the “Correspondence”) to Gladstone
Commercial Corporation (the “Company”) regarding the review of the above-referenced filing by the
staff (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”). Our
responses to each item raised in the Correspondence are provided below. For your convenience we
have restated the comments provided by the Staff prior to each of our corresponding responses
below.
Comment 1 — General:
We note that you appear to have used your old Exchange Act reporting number on the cover page
of your Form 10-K and your most recent Form 10-Q. In future filings, please use your current
Exchange Act reporting number (001-33097) or advise.
Comment 1 — Response:
The Company will use the current Exchange Act reporting number (001-33097) in all future
filings.
Comment 2 — Item 2. Properties, Page 22:
Please provide us a schedule of leases expiring in the next ten years, including the total
area in square feet covered by such leases, the annual rental represented by such leases, and the
percentage of gross annual rental represented by such leases on a portfolio basis. In addition,
please tell us the geographic areas in which your properties are located on a portfolio basis.
Confirm that you will provide similar disclosure in future filings.
Comment 2 — Response:
The Company has provided two additional tables below, which reflect the schedule of leases
expiring in the next ten years and the geographical areas in which the Company’s properties are
located. The Company will provide these tables in future filings with the Commission.
The following table summarizes the lease expirations by year for the Company’s properties for
leases in place as of December 31, 2008:
Year of Lease
Annualized Base
% of Annualized
Expiration
Square Feet
Number of Leases
Rental Revenue
Base Rent
2009
17,432
1
$
211,183
0.5
%
2010
215,581
3
1,409,691
3.4
%
2011
30,268
1
536,324
1.3
%
2012
479,982
3
4,429,603
10.7
%
2013
438,422
6
4,670,909
11.2
%
2014
614,132
5
3,055,683
7.4
%
2015
879,444
8
6,494,747
15.6
%
2016
898,257
5
4,195,156
10.1
%
2017
102,200
1
922,927
2.2
%
2018
59,894
1
268,042
0.7
%
2019+
2,594,344
17
15,344,993
36.9
%
Total
6,329,956
51
$
41,539,258
100
%
The following table summarizes the geographic locations of the Company’s properties for
leases in place as of December 31, 2008:
Number of
Annualized Base
% of Annualized
State
Square Feet
Leases
Rental Revenue
Base Rent
Ohio
1,185,411
11
$
7,366,813
17.7
%
Minnesota
547,800
3
5,211,470
12.5
%
North Carolina
695,876
6
3,777,316
9.1
%
Pennsylvania
623,375
4
3,008,444
7.2
%
Texas
188,178
4
2,353,410
5.7
%
Michigan
596,104
2
2,195,838
5.3
%
Illinois
164,131
2
2,186,019
5.3
%
Massachusetts
338,508
3
2,122,753
5.1
%
All Other States
1,990,573
16
13,317,195
32.1
%
Total
6,329,956
51
$
41,539,258
100
%
2
The Company acknowledges that the adequacy and accuracy of the disclosure in the filing
is the responsibility of the Company. The Company acknowledges that 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. The Company also acknowledges that Staff comments may not be asserted
as a defense in any proceeding initiated by the Commission or any person under the federal
securities laws of the United States.
Please direct any further questions or comments concerning the filing or this response letter
to the undersigned at (703) 287-5853.
Sincerely,
/s/ Danielle Jones
Danielle Jones
Chief Financial Officer
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