July 19, 2019

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, 2018
           Filed October 31, 2018
           File No. 001-29190

Dear Mr. Gaivironsky:

        We have reviewed your May 15, 2019 response to our comment letter and
have the
following comment. In our comment, we may ask you to provide us with
information so we may
better understand your disclosure.

       Please respond to this comment 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
comment applies to your facts and circumstances, please tell us why in your
response.

      After reviewing your response to this comment, we may have additional
comments. Unless we note otherwise, our references to prior comments are to
comments in
our March 25, 2019 letter.

Form 20-F for the fiscal year ended June 30, 2018

Item 5. Operating and Financial Review and Prospects
Effects of Foreign Currency Fluctuations, page 183

1.    Given the significance of your investment properties to your financial
statements and the
      significant judgments management must make to internally develop inputs
due to your
      operating environment unique to Argentina, please expand your disclosure
with respect to
      how you determine the fair value of your shopping malls to provide clear
disclosure of
      how these inputs, including estimated WACC, are calculated along with a
discussion of
      any changes in these estimates from period to period in response to
changing economic
      conditions. Please enhance your disclosure to provide greater
transparency to users of the
      financial statements about the methods and specific assumptions utilized
in your
      calculation of WACC, including any US-based assumptions, adjustments for
country risk
 Matias I. Gaivironsky
CRESUD INC
July 19, 2019
Page 2
         premium, assumptions for cost of debt and any other significant
estimates or assumptions.
         Refer to paragraph 91(b) of IFRS 13 and paragraph 125 of IAS 1.
       You may contact Eric McPhee at 202-551-3693 or Robert Telewicz at
202-551-3438 if
you have questions regarding comments on the financial statements and related
matters.



                                                             Sincerely,
FirstName LastNameMatias I. Gaivironsky
                                                             Division of
Corporation Finance
Comapany NameCRESUD INC
                                                             Office of Real
Estate and
July 19, 2019 Page 2                                         Commodities
FirstName LastName