<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
Mail Stop 3233

                                                                      October
11, 2018


     Via Email
     Mr. David K. Holeman
     Chief Financial Officer
     Whitestone REIT
     2600 South Gessner, Suite 500
     Houston, TX 77063

            Re:      Whitestone REIT
                     Form 10-Q
                     Response dated September 11, 2018
                     File No. 001-34855

     Dear Mr. Holeman:

            We have reviewed your September 11, 2018 response to our comment
letter and have the
     following comments. In some of our comments, we may ask you to provide us
with information
     so we may better understand your disclosure.

            Please respond to these comments within ten business days by
providing the requested
     information or advise us as soon as possible when you will respond. If you
do not believe our
     comments apply to your facts and circumstances, please tell us why in your
response.

            After reviewing your response to these comments, we may have
additional comments.
     Unless we note otherwise, our references to prior comments are to comments
in our August 27,
     2018 letter.

     Note 6. Investment in Real Estate Partnership, page 13

     1.     We note from your response to comment 1 that you do not believe
that collection of the
            consideration owed to you under the Contribution is probable.
Please expand to describe
            to us the following:

                  a. Your consideration of the cash flows, loan-to-value
ratios, and other pertinent
                     information for Pillarstone to support your conclusion, in
light of the lack of
                     disclosure in Pillarstone's public filings about
uncertainties in its ability to satisfy
                     obligations as they become due.
 David K. Holeman
Whitestone REIT
October 11, 2018
Page 2

          b. Your recourse should Pillarstone, a company majority owned by your
CEO, fail to
             pay amounts owed to you by the agreed-upon date of December 8,
2018.

          c. Reasons for considering (i) the contingent redemption of
Pillarstone OP units and
             (ii) the assumption of $50.4 million of liabilities in the
assessment of probability
             for collection of the consideration from Pillarstone, as the
redemption does not
             appear to represent a present obligation from Pillarstone and
Pillarstone owes the
             $50.4 million to other parties and not you.

2.     We note that the assets transferred to Pillarstone represent
substantially all of its
       operations. Notwithstanding the comment above, please tell us your
consideration of
       ASC 360-10-35-21 in determining whether to test the assets for
recoverability. If you
       tested the assets for recoverability, describe to us the outcome of that
test.

Item 4. Controls and Procedures, page 52

3.     We acknowledge your response to comment 2 and continue to consider it.

       You may contact Kristi Marrone at (202) 551-3429 or me at (202) 551-3395
with any
questions.


                                                           Sincerely,

                                                           /s/ Isaac Esquivel

                                                           Isaac Esquivel
                                                           Staff Accountant
                                                           Office of Real
Estate and
                                                           Commodities
</TEXT>
</DOCUMENT>
