0001104659-18-054502.txt : 20181004 0001104659-18-054502.hdr.sgml : 20181004 20180830162405 ACCESSION NUMBER: 0001104659-18-054502 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20180830 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Black Creek Diversified Property Fund Inc. CENTRAL INDEX KEY: 0001327978 STANDARD INDUSTRIAL CLASSIFICATION: REAL ESTATE INVESTMENT TRUSTS [6798] IRS NUMBER: 300309068 STATE OF INCORPORATION: MD FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 518 SEVENTEENTH STREET STREET 2: 17TH FLOOR CITY: DENVER STATE: CO ZIP: 80202 BUSINESS PHONE: (303)228-2200 MAIL ADDRESS: STREET 1: 518 SEVENTEENTH STREET STREET 2: 17TH FLOOR CITY: DENVER STATE: CO ZIP: 80202 FORMER COMPANY: FORMER CONFORMED NAME: Dividend Capital Diversified Property Fund Inc. DATE OF NAME CHANGE: 20120712 FORMER COMPANY: FORMER CONFORMED NAME: Dividend Capital Total Realty Trust Inc. DATE OF NAME CHANGE: 20050520 CORRESP 1 filename1.htm

 

August 30, 2018

 

VIA EDGAR

 

Ms. Stacie Gorman, Attorney-Adviser

U.S. Securities and Exchange Commission

Division of Corporation Finance

100 F Street, NE, Mail Stop 3010 CF/AD8

Washington, DC  20549

 

Re:          Black Creek Diversified Property Fund Inc.
Registration Statement on Form S-11, as amended
File No. 333-222630

 

Ladies and Gentlemen:

 

In accordance with Rule 461 under the Securities Act of 1933, Black Creek Diversified Property Fund Inc. (the “Company”) hereby requests that the Securities and Exchange Commission (the “Commission”) accelerate the effective date of the above-referenced Registration Statement in order that the Registration Statement shall become effective at 9:00 A.M. (EDT) on September 5, 2018 or as soon thereafter as practicable.

 

In connection with the acceleration request, the Company hereby acknowledges that:

 

·                  should the Commission or the staff, acting pursuant to delegated authority, declare the Registration Statement effective, it does not foreclose the Commission from taking any action with respect to the Registration Statement;

 

·                  the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the Registration Statement effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the Registration Statement; and

 

·                  the Company may not assert this action as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

 

Please contact Chris Stambaugh at 919-786-2040 of DLA Piper LLP (US), counsel to the Company, with any questions about this acceleration request.  Please notify us when the delegated authority copy of the order of the Commission declaring the Registration Statement effective has been executed.

 

 

Very truly yours,

 

 

 

Black Creek Diversified Property Fund Inc.

 

 

 

 

By:

/s/ Lainie P. Minnick

 

Name:

Lainie P. Minnick

 

Title:

Managing Director, Chief Financial Officer and Treasurer