April 28, 2025

Timothy G. McHugh
Co-President & Chief Financial Officer
Welltower Inc.
4500 Dorr Street
Toledo, Ohio 43615

       Re: Welltower Inc.
           Form 10-K for Fiscal Year Ended December 31, 2024
           File No. 001-08923
Dear Timothy G. McHugh:

       We have reviewed your filing and have the following comment.

       Please respond to this letter 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 comment applies to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to this letter, we may have additional
comments.

Form 10-K for Fiscal Year Ended December 31, 2024
Item 1. Business, page 2

1.     Please tell us, and revise future filings, to discuss your data science
platform and the
       status of any AI-integration efforts. In this regard, we note your
disclosure on page 40
       that you are integrating generative AI tools into your systems. We also
note discussion
       of your data science platform during the conference call to discuss your
fourth quarter
       2024 results held on February 15, 2025, including that it is
"industry-leading" and one
       of the sources of your competitive advantage; and in the March 7, 2025
press release
       titled "Welltower Reveals a New Visual Identity" posted on your website.
        We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence
of action by the staff.

       Please contact Peter McPhun at 202-551-3581 or Jennifer Monick at
202-551-3295 if
you have questions regarding comments on the financial statements and related
matters. Please contact Benjamin Holt at 202-551-6614 or Jeffrey Gabor at
202-551-2544
with any other questions.
 April 28, 2025
Page 2



                 Sincerely,

                 Division of Corporation Finance
                 Office of Real Estate & Construction