[Capital Trust, Inc. Letterhead]
June 21, 2011
VIA EDGAR AND BY UPS
U.S. Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, D.C. 20549-6010
Attention: Folake Ayoola
Re: Capital Trust, Inc.
Registration Statement on Form S-3
Filed June 1, 2011
File No. 333-174646
Ladies and Gentlemen:
At the request of the Staff of the U.S. Securities and Exchange Commission (the Commission) pursuant to its letter of comment, dated June 17, 2011, on behalf of Capital Trust, Inc. (the Company), the Company hereby 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 action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and
· the Company may not assert staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
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Very truly yours, | |
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CAPITAL TRUST, INC. | |
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By: |
/s/ Stephen D. Plavin |
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Name: |
Stephen D. Plavin |
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Title: |
Chief Executive Officer |
cc: Michael L. Zuppone