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Published on September 20, 2007
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John O. Newell |
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Goodwin Procter LLP |
August 29, 2007
VIA EDGAR AND TELECOPIER
Ms. Pam Howell
Special Counsel
United States Securities and Exchange Commission
Division of Corporation Finance
Mail Stop 3561
100 F Street, N.E.
Washington, D.C. 20549
Re: AvalonBay Communities, Inc.
Definitive 14A
Filed April 2, 2007
File No.
1-12672
Dear Ms. Howell:
This letter is submitted on behalf of AvalonBay Communities, Inc. (the Company) in connection with the comments of the staff of the Division of Corporation Finance (the Staff) of the Securities and Exchange Commission (the Commission) with respect to the Companys Definitive Schedule 14A filed on April 2, 2007 (file no. 1-12672) ( the Proxy Statement), as set forth in your letter dated August 21, 2007 to Bryce Blair, Chairman and Chief Executive Officer of the Company (the Comment Letter).
The Company hereby requests that the Staff accept a deferral of the date for the Companys response to the Comment Letter to October 22, 2007. This request is based on the need to obtain thorough review by the Companys senior management and the Compensation Committee of the Board of Directors before the Companys responses are submitted to the Staff. In particular, the Company is requesting the deferred response date because of scheduling factors that will affect the Compensation Committees review.
Ms. Howell
August 29, 2007
Page 2
Based on our telephone conversations, I believe that the Companys proposal will be acceptable to the Staff. If there are questions or concerns about the Companys request after review of this letter, please do not hesitate to contact me by telephone at (617) 570-1475 or by electronic mail at jnewell@goodwinprocter.com.
Very truly yours,
/s/ John O. Newell
John O. Newell
cc: Edward
J. Schulman
Senior Vice President-General Counsel