United States securities and exchange commission logo
March 11, 2024
Peter Tropoli
General Counsel & Corporate Secretary
Whitestone REIT
2600 S. Gessner Road, Suite 500
Houston, TX 77063-3223
Re: Whitestone REIT
DEFA14A filed March
7, 2024
File No. 001-34855
Dear Peter Tropoli:
We have reviewed your filing and have the following comment. In
our comment, we may
ask you to provide us with information so we may better understand your
disclosure.
Please respond to this comment by providing the requested
information or advise us as
soon as possible when you will respond. If you do not believe our
comment applies to your facts
and circumstances, please tell us why in your response.
After reviewing your
response to this comment, we may have additional comments.
DEFA14A filed March 7, 2024
General
1. Communications made in
reliance on Rule 14a-12 must identify the participants in the
solicitation and
describe the participants direct or indirect interests. Please note
that
the legend must advise
security holders where they can currently obtain such information,
which requirement is
not satisfied by including a general reference to filings made by the
soliciting party. In
this respect, we note your statements that "[i]nformation regarding
the ownership of the
Company s trustees and executive officers in Company common
shares and other
securities is included in their SEC filings on Forms 3, 4, and 5..." and
"[i]nformation can also
be found in the Company s other SEC filings, including the
Company s Annual
Report on Form 10-K." Please revise to provide more specific
references. Refer to
Rule 14a-12(a)(1)(i) and Question 132.03 of the Compliance and
Disclosure
Interpretations for Proxy Rules and Schedules 14A/14C, available
at
https://www.sec.gov/corpfin/proxy-rules-schedules-14a-14c-cdi.htm.
We remind you that the filing persons are responsible for the
accuracy and adequacy of
their disclosures, notwithstanding any review, comments, action or
absence of action by the staff.
Peter Tropoli
Whitestone REIT
March 11, 2024
Page 2
Please direct any questions to David Plattner at 202-551-8094.
FirstName LastNamePeter Tropoli Sincerely,
Comapany NameWhitestone REIT
Division of
Corporation Finance
March 11, 2024 Page 2 Office of Mergers
and Acquisitions
FirstName LastName