Mail Stop 4561

      							December 2, 2005

Via U.S. Mail and Fax (713) 866-6049
Mr. Stephen C. Richter
Executive Vice President and Chief Financial Officer
Weingarten Realty Investors
2600 Citadel Plaza Drive
P.O. Box 924133
Houston, TX 77292-4133

	RE:	Weingarten Realty Investors
      Form 10-K for the fiscal year ended December 31, 2004
		Filed March 16, 2005
		File No. 1-09876

Dear Mr. Richter:

      We have reviewed your response letter dated November 22,
2005
and have the following additional comments.  In our comments, we
ask
you to provide us with supplemental information so we may better
understand your disclosure.  After reviewing this information, we
may
or may not raise additional comments.

	Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your
filings.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.



Note 2.  Newly Adopted Accounting Pronouncements, page 40

1. We have reviewed your response to prior comment 1.  In future
filings, please revise your disclosure to include the information
contained in your response.




Note 14.  Commitments and Contingencies, page 48

2. We have reviewed your response to prior comment 2.  Please
clarify
whether you or any of your subsidiaries are the original sellers
of
property to any of the joint ventures.  If so, then the option
held
by the outside limited partners to put their interest to the
partnership would preclude a sale under paragraph 26 of SFAS 66.
In
which case, please provide us with an analysis for each of these
entities to determine whether the arrangement represents a
financing,
leasing, or profit sharing based on the terms of the option and
the
likelihood that the option will be exercised.

3. Please tell us how you have considered the provisions of EITF
00-4
and EITF 00-19 in determining your accounting for the put options
held by the outside limited partners in the joint ventures.

*    *    *    *

      As appropriate, please amend your filing and respond to
these
comments within 10 business days or tell us when you will provide
us
with a response.  You may wish to provide us with marked copies of
the amendment to expedite our review.  Please furnish a cover
letter
with your amendment that keys your responses to our comments and
provides any requested information.  Detailed cover letters
greatly
facilitate our review.  Please understand that we may have
additional
comments after reviewing your amendment and responses to our
comments.

	We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings to be certain that they
have provided all information required under the Securities
Exchange
Act of 1934 and that they have provided all information investors
require for an informed investment decision.  Since the company
and
its management are in possession of all facts relating to a
company`s
disclosure, they are responsible for the accuracy and adequacy of
the
disclosures they have made.

	In connection with responding to our comments, please
provide,
in writing, a statement from the company acknowledging that

* the company is responsible for the adequacy and accuracy of the
disclosure in 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

* the company 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.



      In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in our review of your filings or
in
response to our comments on your filing.

      You may contact William Demarest, Staff Accountant, at (202)
551-3432 or me at (202) 551-3780 with any questions.

							Sincerely,



							Linda van Doorn
							Senior Assistant Chief
Accountant


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Mr. Stephen C. Richter
Weingarten Realty Investors.
December 2, 2005
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