Subject: File No. 81-939
From: douglas Hercher
Affiliation: Private Investor

May 15, 2013

Dear Commission:

As a private investor who holds shares in both the Series B and Series C preferred stock issues related to W2007 Grace, I respectfully ask that the Company's request for an exemption under Section 12(H) be declined.

The beneficial owner of the common equity in this company is a well-capitalized, highly sophisticated financial investor which is perfectly capable of managing the disclosure requirements of a billion dollar business.

At this time, in light of the failure of the company to pay dividends to its preferred holders, I believe the Commission's primary concern should be to ensure that the shareholders of these public shares receive as much information about the financial prospects of the company they've invested in as is reasonably available.

The claim by W2007 Grace that an exemption is warranted because they believe there are fewer than 300 actual beneficial owners is entirely unsubstantiated. Absent a more compelling case from Grace, anchored one would hope by data not conjecture, the benefit of the doubt must surely go to the hundreds of owners of these securities.