Capital Trust, Inc.
410 Park Avenue, 14th Floor
New York, New York 10022
October 29, 2012
VIA EDGAR
U.S. Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Re: | Capital Trust, Inc. |
Preliminary Proxy Statement on Schedule 14A
Filed October 15, 2012
File No. 001-14788
Ladies and Gentlemen:
In connection with the above-referenced filing, Capital Trust, Inc. hereby acknowledges that:
| it is responsible for the adequacy and accuracy of the disclosure in its Preliminary Proxy Statement on Schedule 14A (the Filing); |
| staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the Filing; and |
| it may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. |
Please direct any questions with respect to the foregoing to Michael L. Zuppone of Paul Hastings LLP at (212) 318-6906.
Sincerely,
/s/ Geoffrey G. Jervis
Geoffrey G. Jervis
Chief Financial Officer
cc: Michael L. Zuppone, Esq.