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LETTER TO THE S.E.C.

COGDELL SPENCER INC.

4401 Barclay Downs Drive, Suite 300

Charlotte, North Carolina 28209-4670

October 24, 2005

Securities and Exchange Commission

100 F Street

Washington, D.C. 20549-4561

    Re:

    Cogdell Spencer Inc.

    Registration Statement on Form S-11 (File No. 333-127396)

    Tandy Statement

Ladies and Gentlemen:

In regards to the above reference registration statement (the “Registration Statement”), we
acknowledge the following:

    •

    The action of the Commission or the staff, acting pursuant to
delegated authority, in declaring the Registration Statement
effective, does not foreclose the Commission from taking any action
with respect to the Registration Statement.

    •

    The action of the Commission or the staff, acting pursuant to
delegated authority, in declaring the Registration Statement
effective does not relieve the Company from its full responsibility
for the accuracy and adequacy of the disclosure in the Registration
Statement.

    •

    The Company may not assert staff comments and the staff’s action in
declaring the Registration Statement effective as a defense in any
proceeding initiated by the Commission or any person under the
federal securities laws of the United States.

The Company hereby confirms that it is aware of its obligations under the Securities Act and the
Securities Exchange Act of 1934, as amended.

    Very truly yours,

COGDELL SPENCER INC.

    By:
    /s/ Frank C. Spencer

    Name:
    Frank C. Spencer

    Title:
    Chief Executive Officer and President