February 4, 2025 David Smith Chief Financial Officer Innovative Industrial Properties, Inc. 1389 Center Drive, Suite 200 Park City, UT 84098 Re: Innovative Industrial Properties, Inc. Form 10-K for the year ended December 31, 2023 File No. 001-37949 Dear David Smith: We have completed our review of your filing. 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. Sincerely, Division of Corporation Finance Office of Real Estate & Construction cc: Carolyn Long