April 1, 2008

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C.  20549

Attention:  Kristina Aberg

Re:	Winthrop Realty Trust
	Registration Statement on Form S-3
	File No. 333-148813

Gentlemen:

Pursuant to Rule 461 of the General Rules and Regulations promulgated under the Securities Act of 1933, Winthrop Realty Trust (the “Company”), hereby requests that its Registration Statement initially filed with the Securities and Exchange Commission (the “Commission”) on January 23, 2008, as amended by Amendment No. 1 (Registration No. 333-148813), be declared effective at 4:00 p.m. PM on April 10, 2008, or as soon thereafter as practicable.

The Company 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 Company acknowledges that 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 represents that it will not assert 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.

Very truly yours,

WINTHROP REALTY TRUST

By:	/s/ Peter Braverman
Name:	Peter Braverman
Title:	President