corresp
September 27, 2010
VIA FACSIMILE AND EDGAR
Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, D.C. 20549
Attention: Kevin Woody, Branch Chief
Howard Efron, Staff Accountant
Telecopier Number: (703) 813-6984
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Re: |
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First Industrial Realty Trust, Inc.
Form 10-K for the year ended December 31, 2009
Form 10-Q for the quarterly period ended March 31, 2010
Definitive Proxy Statement on Schedule 14A filed April 2, 2010
File No. 1-13102 |
Dear Messrs. Woody and Efron:
We are writing to respond to the comment of the Staff contained in a letter, dated September
22, 2010, relating to the above-referenced filings of First Industrial Realty Trust, Inc. (the Company). Set forth
below is the comment (in italics) as set forth in the Staffs letter and immediately below the
comment is the response of the Company.
Form 10-K for the fiscal year ended December 31, 2009
Item 7 Managements Discussion and Analysis of Financial Condition and Results of
Operations
Critical Accounting Policies, page 30
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We note your enhanced discussion in the second paragraph of your response to prior comment 1
related to assumptions used in your impairment testing. Please confirm that you will enhance
your discussion within the Managements Discussion and Analysis of Financial Condition and
Results of Operations of future filings to address significant changes in assumptions such as
those which you had made in response to the severe recession. |
Management hereby confirms that it will enhance its discussion within the
Managements Discussion and Analysis of Financial Condition and Results of
Operations in future filings to address significant changes in its assumptions.
In connection with responding to the above comment, the Company hereby acknowledges that it is
responsible for the adequacy and accuracy of the disclosures in the filings; staff comments or
changes to disclosure in response to staff comments do not foreclose
Securities and Exchange Commission
Attention: Kevin Woody, Branch Chief
Howard Efron, Staff Accountant
September 27, 2010
Page 2
the Commission from taking any
action with respect to the filings; 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. If you have any questions about any of the Companys responses to
your comments or require further explanation, please do not hesitate to telephone me at (312)
344-4380.
Very truly yours,
/s/ Scott Musil
Scott Musil
Enclosures
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cc: |
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Bruce W. Duncan
John H. Clayton
William E. Turner II |