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CORRESP
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Prepared and filed by St Ives Burrups

  F  R  I  E  D  M  A  N     B  I  L  L  I  N  G  S      R  A  M  S  E  Y

December
    13, 2004

Friedman, Billings, Ramsey & Co., Inc.

  1001 19th Street North

  Arlington, Virginia 22209

  Securities and Exchange Commission

  Division of Corporation Finance

  450 Fifth Street, N.W.

  Washington, DC 20549

 Re:
Feldman Mall Properties, Inc.

  Registration Statement on Form S-11

  (File No. 333-118246)

 Ladies and Gentlemen:

Pursuant to Rule 460 of the General Rules and
    Regulations under the Securities Act of 1933, as amended (the “Securities
    Act”), we, on behalf of ourselves and the several Underwriters,
    wish to advise you that in connection with the above-captioned Registration
    Statement, copies of the Preliminary Prospectus dated November 24, 2004 were
    distributed during the period November 24, 2004 through December 14, 2004
as follows:

Preliminary Prospectus

     35

    to
    Underwriters

     9

    to
    Dealers

     805

    to
    Institutions

    2,808

    to
    Other

    3,657

    Total

     Reference
    is made to the letter from Feldman Mall Properties, Inc. (the “Company”),
    dated December 13, 2004, requesting effectiveness of the Registration Statement
    at 3:00 p.m., Eastern Standard Time on December 15, 2004. In accordance with
    Rule 461 of the General Rules and Regulations under the Securities Act, we
    hereby join in the request of the Company for acceleration of the effective
    date of the above-named Registration Statement so that it becomes effective
    at 3:00 p.m. Eastern Standard Time on December 15, 2004, or as soon thereafter
    as practicable.

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Very truly yours,

FRIEDMAN, BILLINGS, RAMSEY & CO.,
    INC.

    By:
      /s/ James R. Kleeblatt

      Name: James R. Kleeblatt

      Title: Senior Managing Director

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