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One Tabor Center, Suite 1500
1200 Seventeenth Street
Denver, CO 80202
T +1 303 899 7300
F +1 303 899 7333
www.hoganlovells.com
December 19, 2011
VIA EDGAR
Adam F. Turk, Attorney-Advisor
Division of Corporation Finance
Securities and Exchange Commission
100 F. Street, N.E.
Washington, D.C. 20549
Division of Corporation Finance
Securities and Exchange Commission
100 F. Street, N.E.
Washington, D.C. 20549
Re: | Apartment Investment and Management Company | |||||
AIMCO Properties, L.P. | ||||||
Registration Statement on Form S-4 | ||||||
Filed July 28, 2011 | ||||||
File No.: 333-175847 |
Dear Mr. Turk:
Apartment Investment and Management Company (“Aimco”) and AIMCO Properties, L.P. (“Aimco OP”) are today filing an amendment to the Registration Statement (File No. 333-175847) on Form S-4 (the “NPI 4 Form S-4”) referenced above. The NPI 4 Form S-4 relates to the merger of National Property Investors 4.
We hereby confirm, on behalf of Aimco and Aimco OP, that the changes made to the NPI 4 Form S-4 are similar in nature to those that were previously made by Aimco and Aimco OP in the amendments to three Registration Statements on Form S-4 (File Nos. 333-175843, 333-175848 and 333-175853), filed with the Securities and Exchange Commission on November 15, 2011 (the “Prior Filings”). The changes made to the NPI 4 Form S-4 (including opinions filed as exhibits) respond to the Staff’s comments in the same manner as the Prior Filings.
* * * *
If you have any questions regarding the foregoing, please contact Robert Mintz at (303) 899-7399.
Mr. Adem F. Trunk
Securities and Exchange Commission
December 19,2011
Page 2
Securities and Exchange Commission
December 19,2011
Page 2
Respectfully yours,
/s/ Robert Mintz
Robert Mintz
cc: | John Bezzant, Executive Vice President Apartment Investment and Management Company Trent Johnson, Vice President and Assistant General Counsel Apartment Investment and Management Company |