March 15, 2006


Mail Stop 4561

      VIA U.S. MAIL AND FAX (703) 287-5901

Harry Brill
Chief Financial Officer
Gladstone Commercial Corporation
1521 Westbranch Drive
Suite 200
Mclean, VA 22102

Re:	Gladstone Commercial Corporation
	Form 10-K for the year ended December 31, 2005
      Filed March 28, 2006
      File No. 0-50363

Dear Mr. Brill:

      We have reviewed your filing and have the following comment.
In our comment, we ask you to provide us with information so we
may
better understand your disclosure.  After reviewing this
information,
we may or may not raise additional comments.

	Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comment or on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.














Form 10-K

Financial Statements

Consolidated Statement of Operations, page 71

1. We note that you included net unrealized depreciation on
translation of assets and liabilities as part of net income.
Please
tell us how you determined that translation of assets and
liabilities
is part of net income and not part of Other Comprehensive Income.
Cite the specific accounting literature that you are relying upon
in
your response.




*    *    *    *



      As appropriate, please respond to this comment within 10
business days or tell us when you will provide us with a response.
Please furnish a cover letter with your amendment that keys your
response to our comment and provides any requested supplemental
information.  Detailed cover letters greatly facilitate our
review.
Please file your cover letter on EDGAR.  Please understand that we
may have additional comments after reviewing your responses to our
comments.

	We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing reviewed by the staff to
be
certain that they have provided all information investors require
for
an informed decision.  Since the company and its management are in
possession of all facts relating to a company`s disclosure, they
are
responsible for the accuracy and adequacy of the disclosures they
have made.

	In connection with responding to our comments, please
provide,
in writing, a statement from the company acknowledging that:

* the company is responsible for the adequacy and accuracy of the
disclosure in the filing;

* staff comments or changes to disclosure in response to staff
comments do not foreclose the Commission from taking any action
with
respect to the filing; 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.

      In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in our review of your filing or in
response to our comments on your filing.

      You may contact James Webster, Staff Accountant, at (202)
551-
3446 or me, at (202) 551-3486 if you have questions.

						Sincerely,



Daniel L. Gordon
Accounting Branch Chief
Gladstone Commercial Corporation
March 15, 2006


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