Mailstop 3233
                                                                  November 20,
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 October 19, 2018
                    File No. 001-29190

     Dear Mr. Gaivironsky:

            We have reviewed your October 19, 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 September
     21, 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.     We understand that rents from your shopping mall leases are indexed
to tenant revenues,
            that you expect tenant revenue growth to be correlated to Argentine
inflation, and that
            you attribute the appreciation in shopping mall fair values
relative to office fair values to
            those expectations. Please quantify the effect of indexed rents on
your shopping mall fair
 Matias I. Gaivironsky
Cresud Inc.
November 20, 2018
Page 2

       value measurements. Please explain how the increase in nominal cash
flows due to
       indexed rents is, or is not, offset by the use of a nominal discount
rate.

2.     We understand that you do not determine the discount rate implied by the
fair value of
       your office properties for which fair value is measured using comparable
transactions.
       IFRS 13 requires maximization of relevant observable inputs; please
explain why the
       discount rate for office properties is not relevant for measuring the
fair value of other
       commercial investment properties, such as shopping malls.

3.     We understand that you consider your weighted-average cost of capital
(WACC) when
       discounting future cash flows to measure the fair value of your shopping
malls. Please
       explain:
               why your WACC is consistent with market participant assumptions;
and
               How your WACC is adjusted for different risks associated with
each investment
               property.

4.     If the discount rate for office properties is not relevant to the fair
value measurement of
       shopping mall properties, please explain why it is appropriate to use
your enterprise
       WACC to discount the future cash flows of your shopping mall properties.
That is, since
       you hold both shopping mall properties and office properties, if you
believe that shopping
       mall discount rates are not relevant to shopping malls, explain why your
WACC would
       be appropriate for shopping malls.

5.     We understand that you use forward USD/ARS forward rates implied by the
onshore
       futures market for one year to measure the fair value of your shopping
malls, and then
       revert to long-term relative inflation rates in the two currencies.
Please explain how you
       consider other observable sources for forward foreign exchange rates.
For example, we
       observe that certain financial data aggregators publish estimated
non-deliverable forward
       foreign exchange rates for periods up to five years at certain valuation
dates.

       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