Correspondence

CORRESP 1 filename1.htm Correspondence

APPLE REIT NINE, INC.

814 East Main Street

Richmond, Virginia 23219

April 24, 2008

Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, DC 20549

Attn: Michael McTiernan, Special Counsel

Re:

Apple REIT Nine, Inc.

File No. 333-147414

Ladies and Gentlemen:

By separate letter of the same date as this letter, Apple REIT Nine, Inc. (the “Issuer”) has, pursuant to Rule 461 under the Securities Act of 1933, requested acceleration of the effective date of the Issuer’s Registration Statement on Form S-11, Registration No. 333-147414, to April 25, 2008, at 2:00 p.m., or as soon thereafter as practicable.

In connection with its request for acceleration of the effective date of its Registration Statement, the undersigned understands and acknowledges that it is responsible for the accuracy and adequacy of the disclosures made in the Registration Statement.

The undersigned Issuer further understands and acknowledges as follows:

•

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 action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Issuer from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and

•

the Issuer 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,

APPLE REIT NINE, INC.

By:		/s/ David S. McKenney
		David S. McKenney
		President of Capital Markets

[David Lerner Associates Letterhead]

April 24, 2008

Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, DC 20549

Attn: Michael McTiernan, Special Counsel

Apple REIT Nine, Inc.

File No. 333-147414

Dear Mr. McTiernan:

Pursuant to Rule 461 under the Securities Act of 1933, David Lerner Associates, Inc. as Manager Dealer for Apple REIT Nine, Inc., as the issuer (the “Issuer”), requests acceleration of the Issuer’s Registration Statement on Form S-11, Registration No. 333-147414, to April 25, 2008 at 2:00 p.m., or as soon thereafter as practicable.


Sincerely,

David Lerner Associates, Inc.

By		/s/ Alan P. Chodosh
		Alan P. Chodosh
		Senior Vice President and CFO

APPLE REIT NINE, INC.

814 East Main Street

Richmond, Virginia 23219

April 24, 2008

Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, DC 20549

Attn: Michael McTiernan, Special Counsel

Re:

Apple REIT Nine, Inc.

File No. 333-147414

Ladies and Gentlemen:

Pursuant to Rule 461 under the Securities Act of 1933, the undersigned issuer (the “Issuer”) requests acceleration of the effective date of the Issuer’s Registration Statement on Form S-11, Registration No. 333-147414, to April 25, 2008, at 2:00 p.m., or as soon thereafter as practicable.


Sincerely,

APPLE REIT NINE, INC.

By:		/s/ David S. McKenney
		David S. McKenney
		President of Capital Markets