UNITED STATES
                                  SECURITIES AND EXCHANGE COMMISSION
                                              WASHINGTON, D.C. 20549


     DI VISION OF
CORPORATI ON FI NANCE


                                                              June 7, 2021

  By E-Mail

  Peter D. Fetzer, Esq.
  Foley & Lardner LLP
  777 East Wisconsin Avenue
  Suite 3800
  Milwaukee, Wisconsin 53202

           Re:     CIM Commercial Trust Corporation
                   Preliminary Proxy Statement on Schedule 14A filed by
Lionbridge Capital I,
                   LP, Lionbridge Capital, LP, Lionbridge Capital GP, LLC,
Lionbridge GP,
                   LLC, Lionbridge Asset Management, LLC, Gregory Morillo, The
                   Ravenswood Investment Company L.P., Ravenswood Investments
III, L.P.,
                   Ravenswood Management Company, LLC, Robotti & Company
Advisors,
                   LLC, Robotti Securities, LLC, Robotti & Company,
Incorporated, Robert E.
                   Robotti, Thomas D. Ferguson, Mark C. Gelnaw, Raymond V.
Marino II,
                   John S. Moran, and Winthrop Realty Partners, L.P.
                   Filed May 25, 2021
                   File No. 001-13610

                   Soliciting Materials filed pursuant to Rule 14a-12 on May
25, 2021
                   Filed by Lionbridge Capital I, LP et. al.
                   File No. 001-13610

  Dear Mr. Fetzer:

          We have reviewed the above-captioned filings, and have the following
comments. Some
  of our comments may ask for additional information so that we may better
understand the
  disclosure.

          Please respond to this letter by amending the filings and/or by
providing the requested
  information. After reviewing any amendment to the filings and any information
provided in
  reply to these comments, we may have additional comments. If you do not
believe our
  comments apply to your facts and circumstances, and/or do not believe an
amendment is
  appropriate, please tell us why in a written response.

         After reviewing any amendment to your filing and the information you
provide in
  response to these comments, we may have additional comments.
 Peter D. Fetzer, Esq.
Foley & Lardner LLP
June 7, 2021
Page 2

Preliminary Proxy Statement

1.     Please disclose whether the election of your nominees would result in a
change of control
       of the company under any agreements the company has entered into and
quantify the
       effect of such change of control.

Cover Page

2.     Please revise this page to highlight to security holders that they will
be disenfranchised
       with respect to two board seats if they return your proxy card. Also,
revise your proxy
       card to include this information.

Why you were sent this proxy statement, page 2

3.     We note you state certain persons    may be deemed    participants in
your solicitation.
       Please revise to remove doubt from the statement.

Proposal No. 1. Election of Directors, page 9

4.     Please revise Mr. Marino   s biography to describe his business
experience during the past
       five years.

Additional Information, page 23

5.     Please revise the second sentence in this section avoid disclaiming
responsibility for your
       own disclosure.

Soliciting Materials

6.     Please refer to the press release. Provide us with supplemental support
for the statistics
       cited for Winthrop   s past and current REIT work.

7.     You must avoid issuing statements that directly or indirectly impugn the
character,
       integrity or personal reputation or make charges of illegal, improper or
immoral conduct
       without factual foundation. Provide us supplementally, or disclose, the
factual foundation
       for the following statements. Refer to Rule 14a-9. With a view toward
revised future
       disclosure, please provide us with support for your stated beliefs.

                    After years of value destruction and blatant disregard for
good corporate
               governance and the best interests of the Company   s
stockholders, including the
               current Board   s self-serving decision to delay the Annual
Meeting without
               explanation
                    In our view, the Company   s current directors, who bear
responsibility for
               overseeing CMCT   s persistent underperformance and long history
of weak
               governance, have repeatedly demonstrated that they are not
capable and/or willing
 Peter D. Fetzer, Esq.
Foley & Lardner LLP
June 7, 2021
Page 3

               to conduct a credible and fully independent strategic review
process, especially
               when the outcome involves serious conflicts of interest for CIM
management and
               many of its Board members.

8.     Each statement or assertion of opinion or belief must be clearly
characterized as such,
       and a reasonable factual basis must exist for each such opinion or
belief. Support for
       opinions or beliefs should be self-evident, disclosed in the proxy
statement or provided to
       the staff on a supplemental basis. Provide support for the following
statements:

                 The statement by Mr. Ashner:       I have rarely seen a cost
structure or pattern of
               governance more injurious to stockholders than the present
situation at
               CMCT. The overhead consumed is grossly out of line for a
portfolio of this size
               and concentration.

                 Your belief that       a bloated cost structure, and
excessively generous service
               agreements that benefit the Company's external operator and
administrative
               services provider...

9.     Please provide us supplemental support for your disclosure that Walker
and Dunlop have
       provided you with a highly confident letter relating to the company   s
financing.

         We remind you that the filing persons are responsible for the accuracy
and adequacy of
their disclosures, notwithstanding any review, comments, action or absence of
action by the staff

       Please direct any questions to me at (202) 551-3619.

                                                              Sincerely,

                                                              /s/ Daniel F.
Duchovny
                                                              Daniel F.
Duchovny
                                                              Special Counsel
                                                              Office of Mergers
and Acquisitions