SEC Company Response from Columbia Equity Trust, Inc. (CIK 0001316710) — Jun 2, 2005
Columbia Equity Trust, Inc. (CIK 0001316710)
Date: June 2, 2005 · CIK: 0001316710 · Accession: 0000950133-05-002518
AI Filing Summary & Sentiment
File numbers found in text: 333-122644
Referenced dates: May 5, 2005
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Hunton & Williams LLP
Riverfront Plaza, East Tower
951 East Byrd Street
Richmond, Virginia 23219-4074
Tel 804-788-8200
Fax 804-788-8218
June 1, 2005
VIA OVERNIGHT DELIVERY
Mr. Jeffrey Shady
Mailstop 0409
U.S. Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C. 20549-0409
Re: Columbia Equity Trust, Inc.
Registration Statement No. 333-122644
Dear Mr. Shady:
Reference is made to Amendment No. 2 ("Amendment No. 2") to the Registration
Statement on Form S-11 filed by Columbia Equity Trust, Inc. (the "Company") with
the Securities and Exchange Commission (the "Commission") on May 27, 2005.
Reference is also made to those certain letters, dated May 27, 2005 ("Response
Letter 2") and April 27, 2005 ("Response Letter 1"), respectively, from David C.
Wright of Hunton & Williams LLP to Ms. Karen J. Garnett of the Commission, which
letters responded to certain comments of the staff of the Commission's Division
of Corporation Finance set forth in letters, dated May 17, 2005 ("Comment Letter
2") and March 10, 2005 ("Comment Letter 1"), respectively, from Ms. Garnett to
Oliver T. Carr, III of the Company.
In Response Letter 2, the Company agreed to provide supplementally certain
materials to the Commission. Enclosed please find:
(1) Attached hereto as Exhibit A, limited liability company agreements (in
response to Comment Letter 2 -- comment 2), which agreements include:
o First Amendment to Amended and Restated Operating Agreement of
King I LLC (draft). (King Street)
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Mr. Jeffrey Shady
June 1, 2005
Page 2
- Amended and Restated Operating Agreement of King I LLC, dated
February 20, 2003. (King Street)
- First Amendment to Amended and Restated Operating Agreement of
Madison Place LLC (draft). (Madison Place)
- Operating Agreement of Madison Place, LLC, dated July 16, 2003.
(Madison Place)
- Operating Agreement of Atrium Building, LLC, dated May 2004.
(Atrium)
- Amended and Restated Limited Liability Company Agreement of 15036
Conference Center Drive LLC, dated as of January 1, 2005.
(Independence Center)
- Second Amended and Restated Agreement of Limited Partnership of
1575 Eye Street Associates, by and among Carr Capital 1575 Eye,
LLC, The American Society of Association Executives and Southern
Region Industrial Realty, Inc., dated February 28, 2002. (1575
Eye Street)
- Limited Liability Company Agreement of 14200 Park Meadow Drive
LLC, dated as of March 8, 2005. (Victory Point)
- Limited Liability Company Agreement of Suffolk Holdings LLC,
dated as of March 17, 2005. (Suffolk Building)
(2) Attached hereto as Exhibit B, a draft of the Amended and Restated Agreement
of Limited Partnership of Columbia Equity, LP (in response to Comment
Letter 2 -- comment 5).
Under cover letter dated May 5, 2005 from the undersigned to you (the
"Supplemental Letter"), the Company provided supplementally to the Commission
certain of the materials that it agreed to provide in Response Letter 1. The
following items, enclosed herewith, represent the balance of the open materials
referenced in the Supplemental Letter:
(3) Attached hereto as Exhibit C, a citation index for the previously
unsupported market section source data and copies of market and industry
data that support such data (in response to Comment Letter 1 -- comments 3
and 59).
(4) Attached hereto as Exhibit D, color copies of the artwork that the Company
intends to use in the prospectus (in response to Comment Letter 1 --
comment 4).
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Mr. Jeffrey Shady
June 1, 2005
Page 3
(5) Attached hereto as Exhibit E, copies of the directed share program
materials (in response to Comment Letter 1 -- comment 75).
If you have any questions regarding the foregoing, please do not hesitate to
call David Wright ((804) 788-8638), Greg Cope ((804) 788-8388) or myself.
Sincerely,
/s/ Christopher C. Green
Christopher C. Green
DIRECT DIAL: 804-788-8309
EMAIL: cgreen@hunton.com
FILE NO: 53582.20
cc: Rachel Zablow
Steven Jacobs
David C. Wright
Oliver T. Carr
John A. Schissel
John A. Good
Enclosures
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Exhibit A
(LLC Agreements)
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Exhibit B
(Amended and Restated Agreement of Limited Partnership of Columbia Equity, LP)
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Exhibit C
(Market Section Source Data)
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Exhibit D
(Proposed Artwork - Inside Front and Back Covers of Prospectus)
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Exhibit E
(Directed Share Program Materials)
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