KIMKimco Realty

We note your disclosure on page 16 of your executed leases and leasing spreads. In future Exchange Act periodic reports please clarify the portion of the executed leases that were new leases and those that were renewals or options. Also, please provide balancing disclosure regarding your leasing cost, including tenant improvement cost and leasing commissions, for both new and renewed leases.

Rest of the question

Please disclose the square footage the leasing cost applies to or provide the cost on a per square footage basis.

In response to the Staff's comment, we will, in our future filings, expand our disclosure on executed leases and leasing spreads to include the portion of the executed leases that were new leases and those that were renewals or options. Also, we will provide disclosure regarding the Company’s leasing cost, including tenant improvement cost and leasing commissions, for both new and renewed leases. We will additionally disclose the leasing cost on a per square footage basis. Read in the reply ↗

In future Exchange Act periodic reports please provide disclosure regarding your lease expirations for the next 10 years, stating (i) the number of tenants whose leases will expire, (ii) the total area in square feet covered by such leases, (iii) the annual rent represented by such leases, and (iv) the percentage of gross annual rent represented by such leases.

In response to the Staff's comment, we will, in our future filings, disclose our lease expirations for the next 10 years, including (i) the number of tenants whose leases will expire, (ii) the total area in square feet covered by such leases, (iii) the annual rent represented by such leases, and (iv) the percentage of gross annual rent represented by such leases. Read in the reply ↗

We note the three development projects and the anticipated capital commitments during 2013. In future Exchange Act periodic reports, to the extent you have a significant construction/redevelopment portfolio, please expand your disclosure to include information regarding anticipated completion dates, costs incurred to date and estimated costs to completion.

In response to the Staff's comment, to the extent that the Company has a significant construction/redevelopment portfolio, we will expand our disclosure to include information regarding anticipated completion dates, costs incurred to date and estimated costs to completion. Read in the reply ↗

We note that you have included acquisitions of and improvements to operating real estate on one line item and acquisition of and improvements to real estate under development on a separate line item in the investing section of the cash flow statement. In future filings, please disclose separately the amounts paid for acquisitions separate from improvements for each category.

Rest of the question

In addition, please include a discussion, within your MD&A of your improvements including a breakdown of these expenditures between new development, redevelopment/renovations, tenant allowances and other capital expenditures by year and a discussion of significant fluctuations between years. Lastly, please disclose the amount of soft costs interest and payroll expenditures capitalized for all periods presented with a narrative discussion of significant fluctuations. We urge all who are responsible for the accuracy and adequac y of the disclosure in the filing to be certain that the filing includes the information the Securities Exchange Act of 1934 and all applicable Exchange Act rules require. Since the company and its management are in possession of all facts relating to a c ompany’s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made. In responding to our comments, please provide a written 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 response to the Staff's comment, we will, in our future filings, disclose separately the amounts paid for acquisitions separate from improvements for both operating real estate and real estate under development. Additionally, in future filings, we will include discussion within the MD&A of our improvements including a breakdown of these expenditures between new development, redevelopment/renovations, tenant allowances and other capital expenditures by period and we will include a discussion of significant fluctuations between periods.

Rest of the answer

Also, in future filings we will disclose the amount of soft costs interest and payroll expenditures capitalized for all periods presented with a narrative discussion of significant fluctuations.

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The Company acknowledges 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.

Read in the reply ↗