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SEC Company Response from Seven Hills Realty Trust (SEVN) (CIK 0001452477) (SEVN) — Apr 6, 2009

Seven Hills Realty Trust (SEVN) (CIK 0001452477)
Date: April 6, 2009 · CIK: 0001452477 · Accession: 0001341004-09-000714

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File numbers found in text: 333-156412, 811-22260

Date
April 6, 2009
Author
Vice-President
Form
CORRESP
Company
Seven Hills Realty Trust (SEVN) (CIK 0001452477)

Letter

VIA EDGAR AND ELECTRONIC MAIL Securities and Exchange Commission Division of Investment Management Washington, DC 20549 RE: New RMR Asia Pacific Real Estate Fund (File Nos. 333-156412 & 811-22260)

Dear Mr. Hallock:

Pursuant to Rule 461 of the General Rules and Regulations under the Securities Act of 1933, as amended, New RMR Asia Pacific Real Estate Fund (the "Registrant") hereby requests that the effec­tiveness of the above-referenced Registra­tion Statements on Form N-14 and Form N-2 be accelerated so that they may become effective by 4:00 p.m., Washington, D.C. time, on Wednesday, April 8, 2009, or as soon thereafter as reasonably practicable.

In connection with this request, the Registrant acknowledges that:

(a)

should the Securities and Exchange Commission (the "Commission") or its staff, acting pursuant to delegated authority, declare the above-referenced Registration Statements effective, it does not foreclose the Commission from taking any action with respect to such Registration Statements;

(b)

the action of the Commission or its staff, acting pursuant to delegated authority in declaring the above-referenced Registration Statements effective, does not relieve the Registrant from its full responsibility for the adequacy and accuracy of the disclosure contained in such Registration Statements; and

(c)

the Registrant may not assert this action as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

Very truly
yours,
NEW
RMR ASIA PACIFIC REAL ESTATE FUND

Show Raw Text
CORRESP
1
filename1.htm

    rmrltr.htm

    NEW
RMR ASIA PACIFIC REAL ESTATE FUND

    400
Centre Street

    Newton,
MA 02458

April 6, 2009

    VIA EDGAR
AND ELECTRONIC MAIL

              Mr. H.R. Hallock, Jr.

              Securities and Exchange
      Commission

              Division of Investment
      Management

              100 F Street, N.E.

              Washington, DC 20549

              RE:

              New RMR Asia Pacific Real Estate
      Fund

                (File
      Nos. 333-156412 &
811-22260)

    Dear Mr. Hallock:

    Pursuant to Rule 461 of the General
Rules and Regulations under the Securities Act of 1933, as amended, New RMR Asia
Pacific Real Estate Fund (the "Registrant") hereby requests that the
effec­tiveness of the above-referenced Registra­tion Statements on Form
N-14 and Form N-2 be accelerated so that they may become effective by
4:00 p.m., Washington, D.C. time, on Wednesday, April 8, 2009, or as soon
thereafter as reasonably practicable.

    In connection with this request, the
Registrant acknowledges that:

              (a)

              should
      the Securities and Exchange Commission (the "Commission") or its staff,
      acting pursuant to delegated authority, declare the above-referenced
      Registration Statements effective, it does not foreclose the Commission
      from taking any action with respect to such Registration
      Statements;

              (b)

              the
      action of the Commission or its staff, acting pursuant to delegated
      authority in declaring the above-referenced Registration Statements
      effective, does not relieve the Registrant from its full responsibility
      for the adequacy and accuracy of the disclosure contained in such
      Registration Statements; and

              (c)

              the
      Registrant may not assert this action as a defense in any proceeding
      initiated by the Commission or any person under the federal securities
      laws of the United States.

                Very truly
      yours,

                NEW
      RMR ASIA PACIFIC REAL ESTATE FUND

                By:

      /s/
      Karen Jacoppo-Wood

                Name:  Karen
      Jacoppo-Wood

                Title:
      Vice-President