March 22, 2011

Ms. Cicely LaMothe

Branch Chief

Securities and Exchange Commission

Washington, D.C.  20549

 Re:  American Spectrum Realty, Inc. Form 10-K for Year Ended December 31, 2009 File No. 001-16785

Dear Ms. LaMothe:

Thank you for your letter of March 17.  We have the following responses:

1.           In our restated 2010 quarterly financials, we will treat the LLC interests as fractional real estate interests under ASC 805, Business Combinations, from the date of their acquisition.  Furthermore, in accordance with ASC 810, Variable Interest Entities, we have determined that four of these properties (Commerce Distribution Center, Fishers Indiana Distribution Center, Ohio II Residences and Strongville) should be consolidated.  We will consolidate these properties into our restatements.  We have determined the other four (Pavillions Apartments, Pinecrest Townhomes, University Commons Minnesota and Wildoak Apartments) are not variable interest entities; therefore we intend to account for these under the equity method of accounting.

2.           The managed properties that we plan to consolidate and the quarter in which we plan to include the properties in our restatements are as follows:

		Company’s
Effective Date	Managed Property	Ownership Interest
First Quarter 2010	Strongville Corporate Center	2.2%
Second Quarter 2010	ldine Westfield Self Storage	0.0%
	Centennial Park Apartments	1.0%
	Commerce Distributions Center  *	1.0%
	Dixon & 51st Logistics Center	0.0%
	Fishers Indiana Distribution Ctr	1.0%
	University Fountains Lubbock	0.0%
	Ohio II – Residences	0.1%
	Ohio Commerce Center	0.0%
	Redmond Commerce Center	0.0%
	Springs Commerce Center I	0.0%
	Springs Commerce Center II	0.0%
	Springs Office	0.0%
	University Heights San Marcos	0.0%
	University Springs San Marcos	0.0%
Third Quarter 2010	College Park	0.0%

*  Ownership interest was acquired in September 2010.

Attached is a materiality analysis that reflects the impact of the consolidation of these managed properties on the financial statements in the previous quarters.  The Company has determined that the net income related to the equity interest in the entities that own these properties was approximately $12,000.00 for the year ended December 31, 2010.  In addition, this amount has no impact on the net loss per share amounts.  Therefore, the Company has not recorded this income due to the immaterially of its effect on the financial statements.

______________________________

We also attach a draft of the footnote we would propose to include in our 10-K as our method of restating the first three quarters.  The restatement accounts for both the business combination and the consolidation of certain variable interest entities.  Please confirm that this restatement will resolve your comments.

Sincerely yours,

/s/ Anthony Eppolito

Anthony Eppolito

Chief Financial Officer

cc:  Yolanda Crittendon William J. Carden Chip Werlein Howard F. Hart