March 11, 2025

Ziv Sapir
Chief Executive Officer
CIM Real Estate Finance Trust, Inc.
Comrit Investments 1, Limited Partnership
9 Ahad Ha   am Street
Tel Aviv, Israel 6129101

       Re: CIM Real Estate Finance Trust, Inc.
           Comrit Investments 1, Limited Partnership
           Schedule TO-T/A filed March 10, 2025 filed by Comrit Investments
Ltd. et. al
           File No. 005-87389
Dear Ziv Sapir:

       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.

Schedule TO-T/A filed March 10, 2025
General

1.     We note that on March 10, 2025, you issued a press release stating that
you amended
       the expiration date of the Offer, such that the Offer will expire on
March 11, 2025,
       instead of March 26, 2025. Please advise how publishing the press
release one
       business day before the new expiration date complies with Rule
14d-4(d)(1), which
       requires dissemination of the press release "in a manner reasonably
designed to
       inform security holders of [the] change."
2.     We note your disclosure in the press release that "[t]he minimum period
during
       which the Offer must remain open following any material change in the
terms of the
       Offer is generally 10 business days to allow for adequate dissemination
to
       shareholders." Please advise how keeping the Offer open for one business
day
       following the amendment in the expiration date comports with such
disclosure.
 March 11, 2025
Page 2

        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 Blake Grady at 202-551-8573.



                                                           Sincerely,

                                                           Division of
Corporation Finance
                                                           Office of Mergers &
Acquisitions