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Biggs
Wilkerson, l.c.

Attorneys
at law

[Letterhead]

Michael R. Biggs

mrb@biggswilkerson.com

3500 N. Rock Road, Bldg. 1100

phone 316.684.2929

Wichita, Kansas 67226

316.681.0153                                                                                                                                       Fax

November
7, 2005

Ms. Peggy Kim, Esq.

Senior Counsel

Division of Corporation Finance

United States Securities and

Exchange Commission

100 F. Street, N.E.

Washington, DC 20549

                RE:          ADVISORS REIT I, Inc.

                                Registration
No. 333-124916

Dear Ms. Kim;

                We
are responding to your Comment Letter dated November 1, 2005.  Our responses are formatted to mirror the
references (title and comment #) included in your November 1st correspondence.  The following is offered for your
consideration.  If there is any other
material or information that we may provide to facilitate your review, please
do not hesitate to contact me.

RESPONSE TO COMMENT LETTER DATED NOVEMBER
1, 2005

                General

1.              Please
provide a more detailed response regarding Mr. Sokolosky’s eligibility for the
Rule 3a4-1 safe harbor.  In particular,
Rule 3a4-1(a)(4)(ii)(A) requires that the “associated person primarily
performs, or is intended primarily to perform at the end of the offering,
substantial duties for or on behalf of the issuer otherwise than in connection
with transactions in securities.”

Your
response states that the Board of Directors, of which Mr. Sokolosky is a
member, will have substantial duties following the completion of the offering.”  Nevertheless, as required by the safe harbor,
you do not directly address how Mr. Sokolosky will meet Rule 3a4-1(a)(4)(ii)(A)
beyond describing the duties of the Board.
Please describe in specific detail all of “substantial duties” on behalf
of the issuer Mr. Sokolosky will primarily perform at the end of the
offering.  In order to be able to use
this safe harbor, these duties cannot be in connection with securities
transactions.

Response to Comment #1

                Rule 3a4-1
expressly lists “directors” as a category of persons for whom its safe harbor applies.  Mr. Sokolosky is a duly elected and currently
serving member of the Board of Directors.
Because the Rule also delineates between officers, employees and
directors, Mr. Sokolosky need not provide a level of service commensurate with that
of a full time employee or an officer in order for his efforts to be “substantial.”  Similarly, the Rule does not require that
each associated person be the only person
performing such services: there is nothing in the Rule that suggest that the
qualifying activities cannot be shared responsibilities.

                Mr. Sokolosky’s
duties and post offering activities will be substantial.  ADVISORS REIT I, Inc. is an internally-managed
REIT, employs a single employee, and its Board of Directors is composed of only
4 individuals, including Mr. Sokolosky.
The Board of Directors, of which Mr. Sokolosky is a member, is charged
with managing the business and affairs of Advisors REIT I, Inc. (“Advisors” or
the “Registrant”) under Section 3.01 of its Bylaws and as a matter of corporate
law.  The combination of these factors (legal
and business) necessitates Mr. Sokolosky’s active and substantial
participation.  In other words, there are
a limited number of people available to perform a multitude of on-going tasks.

                It is currently
contemplated that Mr. Sokolosky’ activities will include, but will not be limited
to, participation in the following activities:

•                    Evaluating (both the due diligence reports and financial analyses) a number of potential real estate opportunities for the approximately four to 12 commercial properties that are expected to be actually acquired during the 12 months following the close of the offering;

•                    Reviewing and/or approving the terms and conditions of each potential purchase and future property sale (the negotiations and legal documentation for which could be lengthy and complex, particularly for multi-tenanted properties);

•                    Reviewing and/or approving the terms and conditions of each proposed relationship with all property management companies with whom Advisors contracts to manage the individual commercial properties acquired by Advisors (approximately two to 12 companies);

•                    Evaluating (financial and creditworthiness analysis) and/or approving the terms, depending upon the size and composition of its real estate portfolio, of approximately four to 50 commercial leases anticipated to be entered into by Advisors with potential lessees; as well as their periodic renegotiation ;

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•                    Relationship-building and maintenance with key tenants, vendors, shareholders, as well as the Advisory Directors;

•                    On-going evaluation of Mr. Fritzemeier’s employment performance (Mr. Fritzemeier’s Employment Contract is terminable upon 30 days notice);

•                    On-going evaluation of the financial performance of Advisors;

•                    Evaluating and maintaining the relationships Advisors enjoys with its outside service providers, including its legal, accounting, and real estate professionals; and

•                    Reviewing and implementing Advisor’s overall business plan through the Board’s oversight and decision-making responsibilities (for example, periodic decisions regarding distributions policy).

                The Registrant
anticipates assigning Mr. Sokolosky to one or more Board committees (Audit,
Compensation or both) sometime in the future, probably at its first annual
shareholders’ meeting.  Both committees
meet periodically.  This will be in
addition to the Board’s regularly scheduled quarterly meetings as well as the
preparation for, and attendance at, a number of meetings that will also need to
be held in order to implement Advisors’ business plan and deploy the offering
proceeds.

                Based upon recent past
experience, Advisor’s Board of Directors takes a very active role in contract
negotiations of critical relationships and transactions; not only approving the
basic business terms, but also personally reviewing
the actual documents being negotiated and providing specific language,
instructions and insights to legal counsel.  We have no reason to believe that this level
of participation will subside or that Mr. Sokolosky would not be personally
involved in much of this activity.

                None
of the above described activities will be in connection with securities
transactions.  Furthermore, it would be
erroneous to summarily dismiss his performance of the other more traditional
roles performed by a member of the Board of Directors in applying the “substantial
services” test.

                Overriding
all, Mr. Sokolosky will be subject to a fundamental fiduciary obligation as a
director of the Registrant.  Case law is
well established that an “absentee” director who fails to stay actively engaged
in well-informed oversight of a corporation’s business activities can be
subject to personal liability.  Mr.
Sokolosky takes his board membership seriously and has no interest in incurring
any personal liability by failing to remain engaged in the affairs of the
Registrant.  He will “substantially”
participate in the business of the Registrant following the closing of the
offering.

                Sales Literature

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                Exhibit 99.1

2.              We note
your response to comment 8 in our letter dated October 17, 2005 and your
revised disclosure that distributions earlier than 12 months after the offering
would probably be a return of capital.
Please remove the parentheses and revise to clarify that until you
generate operating cash flows sufficient to pay distributions, you may make
distributions from the proceeds of this offering or from borrowings, which may
include a return of capital.  Similarly,
please revise your disclosure of your distribution policy on pages 6 and 73 to
clarify that you may make distributions from the proceeds of the offering if
you do not generate sufficient operating cash flows to pay distributions.

Response to Comment #2

                                                Attached are
sample pages illustrating our proposed changes to Exhibit 99.1 and the two
paragraphs of the prospectus as referenced in your comment.

Please
note:

                The last sentence of the bottom
paragraph appearing on proposed page 6 of the Prospectus;

                The fourth and fifth sentences
of the first full paragraph appearing at the top of proposed page 73 of the
Prospectus;

                The first bullet point listed
under the “Objectives” section of the brochure (exh. 99.1); and

                The last risk factor listed
under the “Risk Factors” section of the brochure (exh. 99.1).

                If acceptable to you, we would
intend and do undertake to include these revisions in their respective
documents upon filing the next amendment.

                Thank
you for your thoughtful consideration of our responses.  If any of them are confusing or unsatisfactory,
please seriously consider contacting me directly at (316) 684-2929.

                                                                                                                Very
truly yours,

                                                                                                                /s/

                                                                                                                Michael
R. Biggs

MRB: gvg

Enclosures

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  If the minimum offering is sold, we may, in our
  sole discretion, and without prior notice to investors, elect to extend the
  offering to a date no later than March 31, 2006 in states that permit
  extension. Presently, no affiliate has indicated that they intend to purchase
  additional shares for their own account. If they later choose to invest,
  their investment will apply toward meeting the minimum offering amount.
  Investors should not assume that sales of shares to reach the minimum will be
  made solely to investors who have no financial or other interest in the
  offering, or who otherwise are exercising independent investment discretion.
  None of the shares currently held or any additional shares that could be
  purchased by any affiliate in the offering will enjoy any rights that are
  distinct from those that may be enjoyed by all investors purchasing shares in
  the Company.

  Offering Size

  •

  Minimum—1,000,000 shares

  •

  Maximum—2,500,000 shares

  Minimum Investment

  •

  $10,000—Additional shares may be purchased in 25
  share increments.

  (Note: Once you have
  subscribed for shares, your subscription is irrevocable unless we permit you
  to revoke it or it lapses due to the minimum offering amount not being met or
  our abandonment of the offering.)

  Suitability Standards

  •

  Net worth (not including home, furnishings and
  personal automobiles) of at least $45,000 and annual gross income of at least
  $45,000; or

  •

  Net worth (not including home, furnishings and
  personal automobiles) of at least $150,000.

  (Note: Suitability
  standards may vary from state to state. Please see the “Suitability Standards
  and How to Subscribe.”)

  Distribution Policy

  Consistent with our objective of qualifying as a
  REIT, we expect to distribute at least 90% of our REIT taxable income to our
  stockholders. It is possible that we might generate less cash flow than
  taxable income in a particular year. In that event, we may be required to use
  cash reserves, incur debt, or liquidate non-cash assets at rates or
  times that we regard as unfavorable in order to satisfy the distribution
  requirement and avoid corporate income tax and the 4% nondeductible excise
  tax in that year. Some distributions may include a return of capital as
  opposed to being solely a distribution of income.

  Once we have taxable income, our Board of
  Directors intends to declare and pay distributions quarterly thereafter. We
  estimate that an investor might have to wait twelve months following the
  closing of the offering to receive distributions. The amount will typically
  depend on the amount of distributable funds, current and projected cash
  requirements, tax considerations and other factors. However, our Board of
  Directors in its sole discretion may also choose to pay distributions from
  the proceeds of this offering or from borrowings if we do not generate
  sufficient operating cash flows to pay distributions.

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distribution. Therefore,
newly admitted investors, or investors redeeming or transferring shares, will
not receive a distribution for a record date that they are not considered a
stockholder of record.

                Once we have taxable income, our Board of Directors
intends to declare and pay distributions quarterly thereafter. Regardless of
the amount raised, we intend to fully invest the offering proceeds within 12
months of their receipt. Delays in investing the proceeds of the offering could
delay the generation of taxable income and funds available for distribution.
However, the Board of Directors, in its sole discretion, may also decide to pay
distributions from the proceeds of this offering or from borrowings if we do
not generate sufficient operating cash flows to pay distribution. Payments from
other than taxable income may be a return of capital. No interest, if any,
earned on subscription proceeds before their release from escrow, will be
distributed to the subscribers. See “The Offering—Funding Arrangement.”

                We are required to distribute annually at least 90%
of our real estate investment trust taxable income to maintain our objective of
qualifying as a REIT. Generally, income distributed will not be taxable to us
under federal income tax laws if we comply with the provisions relating to
qualification as a REIT. If our available cash is insufficient to make the
distributions, we may obtain the necessary funds by borrowing, issuing new
securities or selling assets. These methods of obtaining funds could affect
future distributions by increasing operating costs. To the extent that
distributions to stockholders exceed our current and accumulated earnings and
profits, the amounts constitute a return of capital for federal income tax
purposes, although these distributions might not reduce stockholders’ aggregate
invested capital.

                Distributions in kind will not be permitted, except
for distributions of readily marketable securities; distributions of beneficial
interests in a liquidating trust established for the dissolution of our Company
and the liquidation of its assets in accordance with the terms of the articles
of incorporation; or distributions of in-kind property, as long as, with
respect to in-kind property, the Board of Directors (i) advises each
stockholder of the risks associated with direct ownership of the property;
(ii) offers each stockholder the election of receiving in-kind property
distributions; and (iii) distributes in-kind property only to those
stockholders who accept the directors’ offer.

                Distributions will be made at the directors’
discretion, depending primarily on the availability of net cash generated from
operations (which includes cash received from tenants except to the extent that
the cash represents a return of principal in regard to the lease of a property
consisting of building only, distributions from joint ventures, and interest
income from borrowers under mortgage loans, less expenses paid), our general
financial condition, and the directors’ obligation to cause us to qualify and
remain qualified as a REIT for federal income tax purposes. We inten