0001144204-16-108624.txt : 20160727 0001144204-16-108624.hdr.sgml : 20160727 20160617060505 ACCESSION NUMBER: 0001144204-16-108624 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 2 FILED AS OF DATE: 20160617 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Global Medical REIT Inc. CENTRAL INDEX KEY: 0001533615 STANDARD INDUSTRIAL CLASSIFICATION: REAL ESTATE INVESTMENT TRUSTS [6798] IRS NUMBER: 464757266 STATE OF INCORPORATION: MD FISCAL YEAR END: 0831 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 4800 MONTGOMERY LANE STREET 2: SUITE 450 CITY: BETHESDA STATE: MD ZIP: 20814 BUSINESS PHONE: 202-524-6851 MAIL ADDRESS: STREET 1: 4800 MONTGOMERY LANE STREET 2: SUITE 450 CITY: BETHESDA STATE: MD ZIP: 20814 FORMER COMPANY: FORMER CONFORMED NAME: SCOOP MEDIA, INC. DATE OF NAME CHANGE: 20111027 CORRESP 1 filename1.htm

June 17, 2016

Jennifer Gowetski

Senior Counsel, Office of Real Estate and Commodities

United States Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549-3561

Re:

Global Medical REIT Inc.

Amendment No. 4 to Registration Statement on Form S-11, Filed June 16, 2016

Amendment No. 3 to Registration Statement on Form S-11, Filed June 15, 2016

Amendment No. 2 to Registration Statement on Form S-11, Filed June 10, 2016
File No. 333-210566

Ladies and Gentlemen:

Set forth below are the responses of Global Medical REIT Inc. (the “Company”, “we,” “us” or “our”), to comments received from the staff of the Division of Corporation Finance (the “Staff”) of the Securities and Exchange Commission (the “Commission”) by letter dated June 16, 2016, with respect to Amendment No. 4 to Registration Statement on Form S-11, filed with the Commission on June 16, 2016 (“Amendment No. 4”), Amendment No. 3 to Registration Statement on Form S-11, filed with the Commission on June 15, 2016 (“Amendment No. 3”), and Amendment No. 2 to Registration Statement on Form S-11, filed with the Commission on June 10, 2016 (“Amendment No. 2”) (together, the “Registration Statement”).

For your convenience, each response is prefaced by the exact text of the Staff’s corresponding comment in bold, italicized text. All references to page numbers and captions correspond to the Registration Statement unless otherwise specified.

General

We note your response to our prior comment 1 and your disclosure that “the public offering price of the shares of common stock in the offering [will be] between $10.00 and $12.00 per share...The last reported sales price of our common stock on the OTC, reported on February 1, 2016, was $0.125.” Where applicable, please revise your disclosure to describe the various factors considered in determining the offering price. Refer to Item 505 of Regulation S-K. In addition, please revise to clarify that your common stock is quoted on the OTC.

RESPONSE: We acknowledge the Staff’s comment and have revised our disclosure on the prospectus cover and page 61 to clarify that our common stock is quoted on the OTC and our disclosure on pages 52 and 61 to describe the various factors considered in determining such offering price.

Securities and Exchange Commission

June 17, 2016

Page 2

Selected Case Studies, page 12

We note your response to our prior comment 2 where you state that “the case studies included in this section are representative of and consistent with our acquisition strategies.” Please revise your disclosure in this section to clarify this point and specifically state whether all your properties are representative and consistent with your acquisition strategies. If you own properties that are not representative and consistent with your acquisition strategies, please revise this section to identify those properties.

RESPONSE: We acknowledge the Staff’s comment and have revised our disclosure on page 12 to clarify that the case studies included in this section are representative of and consistent with our acquisition strategies and to disclose that we believe all of the other properties we currently own are also representative and consistent with our acquisition strategies.

Summary Risk Factors, page 16

We note your response to our prior comment 3 where you state that “as of March 31, 2016 over 95% of our revenues resulted from five tenant-operators.” Please revise the third bullet point in this section to include this information.

RESPONSE: We acknowledge the Staff’s comment and have revised our disclosure on page 16 to disclose that as of March 31, 2016, 95% of our revenues resulted from five tenant-operators.

* * * * *

Securities and Exchange Commission

June 17, 2016

Page 3

Please direct any questions that you have with respect to the foregoing or if any additional supplemental information is required by the Staff, please contact Daniel M. LeBey of Vinson & Elkins L.L.P. at (804) 327-6310.

	Very truly yours,

	GLOBAL MEDICAL REIT INC.

	By:	/s/ David A. Young
	Name:	David A. Young
	Title:	Chief Executive Officer

Enclosures