Writer's Direct Number
Writer's E-mail Address
 212.756.2376
Eleazer.Klein@srz.com



                                         April 24, 2019
VIA E-MAIL AND EDGAR
Christina E. Chalk
Senior Special Counsel, Office of Mergers and Acquisitions

Division of Corporate Finance
U.S. Securities and Exchange Commission
100 F Street, NE
Washington, D.C. 20549

                   Re: Mack-Cali Realty Corporation
                       Amendment No. 1 to Preliminary Proxy Statement (PRRN14A)
                       on Schedule 14A
                       Filed April 22, 2019 by Bow Street LLC, et al.
                       File No. 001-13274

Dear Ms. Chalk:

        On behalf of Bow Street LLC and its affiliates (collectively, "Bow
Street") and the other
filing persons (together with Bow Street, the "Filing Persons") we are
responding to your letter
dated April 23, 2019 (the "SEC Comment Letter") in connection with the revised
preliminary
proxy statement on Schedule 14A filed on April 22, 2019 (the "Revised
Preliminary Proxy
Statement") with respect to Mack-Cali Realty Corporation ("Mack-Cali" or the
"Company"). We
have reviewed the comments of the staff (the "Staff") of the Securities and
Exchange Commission
and respond below. For your convenience, the comments are restated below in
italics, with our
responses following.

        Concurrently with this letter, the Filing Persons are filing a second
revised preliminary
proxy statement on Schedule 14A (the "Second Revised Preliminary Proxy
Statement"). The
Second Revised Preliminary Proxy Statement reflects revisions made in response
to the comments
of the Staff in the SEC Comment Letter, as well as other updating changes.
Capitalized terms used
but not defined herein have the meaning ascribed to such terms in the Second
Revised Preliminary
Proxy Statement.

Schedule 14A

1. Refer to comments 2 and 3 in our prior comment letter dated April 19, 2019
and your response,
including the revised disclosure provided in your amended preliminary proxy
statement. While the
 Ms. Chalk
Page 2
April 24, 2019

revisions to your proxy statement (on page 1, footnotes 1 and 2) provide
clarification on how you
calculated NAV for ApartmentCo, expand to explain the basis for your belief
that ApartmentCo's
stock would trade at NAV. To the extent that such assumption is based on
trading value of other
publicly-traded REITs, explain how they compare to ApartmentCo in terms of
financial leverage
and debt levels.

        In response to the Staff's comment, the Filing Persons have provided
further support to the
assumption that ApartmentCo would trade at net asset value ("NAV") in footnote
2 on page 3 of
the Second Revised Preliminary Proxy Statement. As previously stated in Bow
Street's
preliminary proxy statement, filed on April 16, 2019, and the Revised
Preliminary Proxy
Statement, this NAV represented by approximately $19.20 per share was
calculated based on the
mid-point of management's estimated NAV for Mack-Cali's current residential
assets, Mack-
Cali's Soho Lofts, and Harborside Plaza 4, all of which would be in
ApartmentCo's residential
portfolio. The Filing Persons believe that shares of ApartmentCo would trade
near or at NAV
given a growth profile that is superior to its peers, albeit with higher
leverage. The Filing Persons
note that publicly-listed apartment REITs generally trade at NAV, regardless of
whether they are
highly leveraged. By way of comparison, peers such as Mid-America Apartment
Communities
Inc., Apartment Investment and Management Co., Essex Property Trust, Inc.,
AvalonBay
Communities Inc., Independence Realty Trust, Inc., Equity Residential, Camden
Property Trust,
UDR, Inc., and NexPoint Residential Trust each respectively have loan-to-value
ratios ("LTVs")
of 26%, 33%, 26%, 20%, 50%, 24%, 21%, 27%, and 54%1 as compared to ApartmentCo,
for
which the Filing Persons calculate an LTV of ~44%,2 taking into account current
residential
portfolio in addition to Soho Lofts and Harborside Plaza 4 at Company
valuations. Further, based
on market diligence, the Filing Persons believe strategic interest in such a
REIT would be
significant, suggesting it would trade with a so-called "takeout premium"
embedded in its share
price.

2. See our last comment above. Revise to include a disclaimer about the risk
that the immediate
value provided to Mack-Cali shareholders through your Transaction Proposal
could be less than
your $27-$29 per share estimate.

        In response to the Staff's comment, the Filing Persons have revised
footnote 2 on page 3 of
the Second Revised Preliminary Proxy Statement with added disclosure clarifying
that there is no
assurance or guarantee that any securities of the Company or a spin-off of the
Company will trade
at specific prices. In the same footnote, the Filing Persons have clarified
that the immediate value
provided to Mack-Cali stockholders through the Transaction Proposal could be
less than $27-$29
per share of Mack-Cali common stock.



1Source for Nexpoint Residential Trust: "Nexpoint Residential Trust: Raymond
James Institutional Investors Conference,"
Presentation, page 13 (Mar. 5. 2019.) Source for all other cited LTVs: Citi,
"the Hunter Express," as of March 18, 2019.
2
 ApartmentCo LTV incorporates debt of $2,234m composed of $2,109 of property
debt (as disclosed on page 7 of Mack-Cali's
Q4 Supplement, available on the Mack-Cali webpage (the "Supplement")) and $125m
of capitalized discounting (Page 7,
Supplement); value of $5,075 million comprised of $4,721 million GAV (page 7,
Supplement), $263.5 million of Soho Lofts, and
$90 million Harborside Plaza 4 (page 7, Supplement).


                                                              2
 Ms. Chalk
Page 3
April 24, 2019

3. Refer to comment 5 in our prior comment letter dated April 19, 2019 and your
response,
including the revised disclosure in footnote 3 on page 4 of the revised proxy
statement. Quantify
the "substantial positions" you maintain in the REITs listed, which you cite as
demonstrating Bow
Street's "track-record of heavy investments in REITs."

       In response to the Staff's comment and to avoid the potential for any
confusion by
stockholders on this point, the Filing Persons have removed indications that
Bow Street's track-
record of investments or positions in REITs have been "heavy" and "substantial"
from the Second
Revised Preliminary Proxy Statement.

4. Refer to comment 6 in our last comment letter, and your response. Your
response states that
"currently Bow Street and DWREI are not party to any formal arrangements or
understandings
with respect to the acquisition of Mack-Cali." If those entities are party to
any informal
arrangements or understandings, with respect to the Transaction Proposal or
otherwise, relating
to Mack-Cali, please describe in your revised preliminary proxy statement.
Please revise or
advise.

        In response to the Staff's comment, the Filing Persons respectfully
note that the Filing
Persons are not party to any formal or informal agreement, arrangement or
understanding with
DWREI with respect to the acquisition of the Company beyond the fact that they
jointly submitted
the Transaction Proposal. The Filing Persons have only had preliminary
discussions regarding the
broad parameters of potential arrangements with respect to the Transaction
Proposal. As a result
of the Company's refusal to seriously entertain the Transaction Proposal or
enter into negotiations
regarding such proposal, the Filing Persons have not reached anything amounting
to a formal or
informal agreement, arrangement or understanding with DWREI with respect to an
acquisition of
Mack-Cali or with respect to anything else related to the Company.

                                               ***

        Thank you for your attention to this matter. Should you have any
questions or comments,
or require any further information with respect to the foregoing, please do not
hesitate to call me
at (212) 756-2376.

                                                            Very truly yours,
                                                            /s/ Eleazer Klein
                                                            Eleazer Klein




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