[Letterhead of Paul, Hastings, Janofsky & Walker LLP]

(212) 318-6859 markschonberger@paulhastings.com
April 7, 2009		41193.00082
VIA EDGAR
U.S. Securities and Exchange Commission 100 F Street, NE Washington, DC 20549
Re:	Acadia Realty Trust
	Registration Statement on Form S-3
Ladies and Gentlemen: We, on behalf of Acadia Realty Trust, transmitted via EDGAR a copy of a pre-effective amendment to Acadia Realty Trust’s Registration Statement on Form S-3 for filing under the Securities Act of 1933, as amended. This Registration Statement is being filed pursuant to the guidance set forth in Question 198.06 of the Division of Corporation Finance Securities Act Rules Compliance and Disclosure Interpretations and in response to comments received by the Securities and Exchange Commission on March 30, 2009. Please do not hesitate to contact me with any questions you may have or for any further information you may desire. Sincerely, /s/ Mark Schonberger Mark Schonberger for PAUL, HASTINGS, JANOFSKY & WALKER LLP