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                              December 10, 2020

       David Holeman
       Chief Financial Officer
       Whitestone REIT
       2600 South Gessner, Suite 500
       Houston, Texas 77063

                                                        Re: Whitestone REIT
                                                            Form 10-K for the
Fiscal Year Ended December 31, 2019
                                                            Form 8-K filed on
October 26, 2020
                                                            File Nos. 001-34855

       Dear Mr. Holeman:

               We have limited our review of your filings to the financial
statements and related
       disclosures 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 within ten business days 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.

       Form 8-K filed on October 26, 2020

       General

   1.                                                   It appears that you
have made adjustments in calculating a non-GAAP measure identified
                                                        as EBITDA beyond those
which are typical (e.g., management fee, net of related
                                                        expenses, loss on sale
or disposal of assets, gain on sale from discontinued operations, net
                                                        and EBITDA adjustments
for real estate partnership). Please revise to
                                                        present EBITDA or
rename the non-GAAP measure you have presented. For additional
                                                        guidance, refer to
question 103.01 of the Compliance and Disclosure Interpretations
                                                        regarding Non-GAAP
Financial Measures.
              In closing, we remind you that the company and its management are
responsible for the
       accuracy and adequacy of their disclosures, notwithstanding any review,
comments, action or
       absence of action by the staff.

                                                        You may contact Ameen
Hamady at 202-551-3891 or Shannon Menjivar at 202-551-
 David Holeman
Whitestone REIT
December 10, 2020
Page 2

3856 with any questions.



FirstName LastNameDavid Holeman   Sincerely,
Comapany NameWhitestone REIT
                                  Division of Corporation Finance
December 10, 2020 Page 2          Office of Real Estate & Construction
FirstName LastName