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                            March 28, 2024

       Peter Tropoli
       General Counsel & Corporate Secretary
       Whitestone REIT
       2600 S. Gessner Road, Suite 500
       Houston, TX 77063-3223

                                                        Re: Whitestone REIT
                                                            PRE 14A filed March
18, 2024
                                                            File No. 001-34855

       Dear Peter Tropoli:

              We have reviewed your filing 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 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.

       Preliminary Proxy Statement filed March 18, 2024

       General

   1.                                                   We note that your
preliminary proxy statement was filed under EDGAR tag "PRE 14A,"
                                                        as opposed to EDGAR tag
"PREC14A," the latter of which should be used for contested
                                                        solicitations. Please
keep this in mind for future reference, and please ensure that
                                                        subsequent filings are
filed under the correct EDGAR tag.
   2.                                                   The proxy statement
includes conflicting references regarding whether the Company
                                                        intends to use the
"notice and access" method of delivery. Please clarify and ensure
                                                        consistency throughout
the document.
   3.                                                   Pages 6 and 16 include
references to your Corporate Governance Guidelines' resignation
                                                        policy that applies
during uncontested elections. Please revise to make clear that such
                                                        policy will not apply
to this year's election given that the election is contested.
   4.                                                   Please ensure that
up-to-date information is provided throughout the proxy statement. For
                                                        example, it is unclear
why December 31, 2022 is referred to in the second paragraph
 Peter Tropoli
FirstName
WhitestoneLastNamePeter Tropoli
            REIT
Comapany
March      NameWhitestone REIT
       28, 2024
March2 28, 2024 Page 2
Page
FirstName LastName
         on page 66 and March 31, 2022 is referred to in the second and third
paragraphs on page
         68.
5.       Please provide disclosure that is fully responsive to Item 4(b) of
Schedule 14A.
6.       We see the note to draft on page 70 indicating that disclosure
responsive to Item 5(b) of
         Schedule 14A is forthcoming. Please ensure that all such required
disclosure is included in
         your proxy statement.
7.       The proxy card indicates that the meeting will be held on May 3, 2024,
at 9:00 a.m.
         Central Time, despite such information being omitted everywhere else
in the proxy
         statement. Please advise.
8.       On the proxy card, please list the Erez nominees in alphabetical order
by last name. See
         Rule 14a-19(e)(4).
9.       Please include disclosure regarding the fact that information about
the Erez nominees can
         be found in Erez's proxy statement, which can be accessed, without
cost, on the
         Commission's website. See Item 7(f) of Schedule 14A.
10.      Please disclose how the Company intends to treat proxy authority
granted in favor of the
         Erez nominees if Erez abandons its solicitation or fails to comply
with Rule 14a   19.
         See Item 21(c) of Schedule 14A.
Background of the Solicitation, page 10

11.      Please explain who Mr. Davis and Mr. Sheikman are.
12.      Regarding the paragraph that refers to March 7, 2024, please clarify
that the Erez press
         release announced the nomination of its two candidates and that those
candidates were
         Schanzer and Clark. Please also clarify that the Company's press
release made no mention
         of Mr. Winters. Finally, please correct the subsequent paragraph to
disclose that Erez filed
         a "DFAN14A" on March 7, 2024, rather than March 8, 2024,
notwithstanding the fact that
         there may have been a delay in such filing appearing on the SEC's
website.
Proposal No. 2 - Advisory Vote on Executive Compensation, page 34

13.      We note the following statement: "we expect that, subject to the
voting results of Proposal
         No. 3, the next Say-On-Pay vote will occur at the 2029 Annual Meeting
of Shareholders."
         It is unclear how Proposal No. 3 relates to Proposal No. 2, and it
appears that the next say-
         on-pay vote will occur at the 2025 annual meeting, not 2029. Please
revise, or advise.
        We remind you that the filing persons are responsible for the accuracy
and adequacy of
their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.

         Please direct any questions to David Plattner at 202-551-8094.
 Peter Tropoli
Whitestone REIT
March 28, 2024
Page 3


FirstName LastNamePeter Tropoli   Sincerely,
Comapany NameWhitestone REIT
                                  Division of Corporation Finance
March 28, 2024 Page 3             Office of Mergers and Acquisitions
FirstName LastName