Mailstop 3233
                                                                   July 23,
2018


     Via E-Mail
     Matias I. Gaivironsky
     Chief Financial Officer
     Cresud Inc.
     Moreno 877 24th Floor
     Buenos Aires, Argentina

            Re:      Cresud Inc.
                     Form 20-F for the fiscal year ended June 30, 2017
                     Filed October 31, 2017
                     Response Dated June 11, 2018
                     File No. 001-29190

     Dear Mr. Gaivironsky:

            We have reviewed your June 11, 2018 response to our comment letter
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 within ten business days 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.
     Unless we note otherwise, our references to prior comments are to comments
in our May 14,
     2018 letter.

     Form 20-F for the fiscal year ended June 30, 2017

     Item 5. Operating and Financial Review and Prospects

     Effects of foreign currency fluctuations, page 188

     1.     Please address the following with respect to your response to our
prior comment 1:

                  Please tell us why the most significant fair value increases
have related to your
                  shopping mall properties. In your response, tell us what
portion of the increases in
                  fair value for all periods presented is due to a change in
the peso/USD exchange rate
                  versus other factors (i.e. changes in discount rates).
 Matias I. Gaivironsky
Cresud Inc.
July 23, 2018
Page 2

           In your MD&A you indicate that changes in the peso/USD exchange
rates were a
           significant cause for the changes in fair value of your investment
properties. As such,
           please clarify why your office and other properties did not
experience a rate of
           increase in value similar to the increase experienced in your
shopping mall properties.
           Please address the impact that translation of your projected cash
flows to US dollars
           and then back, for purposes of the discounted cash flows analysis,
has on your
           valuation.
           Please tell us what US dollar-denominated long-term interest rate is
utilized in your
           calculation, and please provide an analysis of the year-over-year
differences in this
           discount rate, the reasons for these changes, and the impact on your
calculation.
           Finally, please expand your disclosure in future filings to more
fully describe your
           valuation methodology, including:
               o Your policy of translating peso denominated cash flow
estimates into USD for
                   purposes of performing your discounted cash flow analysis
and the rationale
                   for this policy.
               o An indication of which assumptions are applied to peso
denominated cash
                   flow estimates and which assumptions are applied to USD
denominated cash
                   flow estimates.

Form 6-K filed May 28, 2018

Investment properties, page 22

2.     We note your response to our prior comment 5. Please confirm that your
disclosure in
       future filings (including interim reports) will include disclosure of
all unobservable inputs
       used in the valuation process. Additionally, please confirm that your
future disclosure
       will include a discussion of the reasons for any material changes in the
value of your
       investment properties from period to period.

       You may contact Eric McPhee at (202) 551-3693 or me at (202) 551-3438
with any
questions.


                                                             Sincerely,

                                                             /s/ Robert F.
Telewicz, Jr.

                                                             Robert F.
Telewicz, Jr.
                                                             Branch Chief
                                                             Office of Real
Estate and
                                                              Commodities