TEXT-EXTRACT 2 filename2.txt August 20, 2019 David Thompson Chief Executive Officer CIM Commercial Trust Corp 17950 Preston Road Suite 600 Dallas, TX 75252 Re: CIM Commercial Trust Corp Form S-3 Filed August 13, 2019 File No. 333-233255 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 Stacie Gorman at 202-551-3585 with any questions. Sincerely, Division of Corporation Finance Office of Real Estate and Commodities cc: Patrick S. Brown, Esq.