Unassociated Document

Reference is made to your letter, dated May 7, 2010 (the “Comment Letter”), with respect to Amendment No. 4 to the Registration Statement on Form S-11 filed by the Empire American Realty Trust, Inc. (the “Company”) with the Commission on April 15, 2010 (No. 333-160093). The Company hereby advises the staff of the Commission that it will prepare a letter to respond to the comments contained in the Comment Letter that relate to the Company’s sales literature. The Company further advises the staff of the Commission that it will not use the sales literature for offers or sales until the Commission has authorized the use of such materials.