TEXT-EXTRACT 2 filename2.txt June 27, 2019 David Thompson Chief Executive Officer CIM Commercial Trust Corporation 17950 Preston Road, Suite 600 Dallas, Texas 75252 Re: CIM Commercial Trust Corporation Registration Statement on Form S-11 Filed June 20, 2019 File No. 333-232232 Dear Mr. Thompson: This is to advise you that we have not reviewed and will not review your registration statement. Please refer to Rules 460 and 461 regarding requests for acceleration. We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. Please contact Jennifer Gowetski at 202-551-3401 with any questions. Sincerely, Division of Corporation Finance Office of Real Estate and Commodities