January 15, 2008

 

VIA EDGAR CORRESPONDENCE AND FACSIMILE
Ms. Karen J. Garnett, Esq.
United States Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, D.C.  20549

 

RE:      Investors Real Estate Trust
            Registration Statement on Form S-3
            Filed on January 8, 2008
            As amended by Pre-Effective
            Amendment No. 1 filed January 15, 2008
            Registration No. 333-148529

 

Ladies and Gentlemen:

            Investors Real Estate Trust (the “Company”), a real estate investment trust organized under the laws of the State of North Dakota, hereby requests that the effective date of the above-referenced Registration Statement be accelerated to 4:00 p.m., Washington, D.C. time, on Tuesday, January 15, 2008, or as soon thereafter as possible.  Please notify the undersigned at 952-401-4802 when the Registration Statement has been declared effective.

            The Company acknowledges that

 

·           should the Commission or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing;∙

·           the Company 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. 

Sincerely, 

INVESTORS REAL ESTATE TRUST

 

/s/ Karin M. Wentz

By:      Karin M. Wentz

Title:    Associate General Counsel