0001104659-17-068097.txt : 20171215 0001104659-17-068097.hdr.sgml : 20171215 20171113215319 ACCESSION NUMBER: 0001104659-17-068097 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20171113 FILER: COMPANY DATA: COMPANY CONFORMED NAME: CIM Commercial Trust Corp CENTRAL INDEX KEY: 0000908311 STANDARD INDUSTRIAL CLASSIFICATION: REAL ESTATE INVESTMENT TRUSTS [6798] IRS NUMBER: 756446078 STATE OF INCORPORATION: MD FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 17950 PRESTON RD STREET 2: SUITE 600 CITY: DALLAS STATE: TX ZIP: 75252 BUSINESS PHONE: 972-349-3200 MAIL ADDRESS: STREET 1: 17950 PRESTON RD STREET 2: SUITE 600 CITY: DALLAS STATE: TX ZIP: 75252 FORMER COMPANY: FORMER CONFORMED NAME: PMC COMMERCIAL TRUST /TX DATE OF NAME CHANGE: 19950111 CORRESP 1 filename1.htm

 

CIM Commercial Trust Corporation

17950 Preston Road, Suite 600

Dallas, TX 75252

 

November 13, 2017

 

Via Edgar

 

U.S. Securities and Exchange Commission,

100 F Street, NE,

Washington, D.C. 20549.

 

Re:               CIM Commercial Trust Corporation
Registration Statement on Form S-11 (Reg. No. 333-218019)

 

Ladies and Gentlemen:

 

Pursuant to Rule 461 promulgated under the Securities Act of 1933, as amended, CIM Commercial Trust Corporation (“CMCT”) respectfully requests that the U.S. Securities and Exchange Commission (the “Commission”) declare the above-referenced registration statement on Form S-11 (the “Registration Statement”) effective on November 16, 2017, at 9:15 a.m. Eastern Time, or as soon thereafter as practicable

 

CMCT acknowledges that:

 

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

 

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

 

·                            CMCT may not assert staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

 


 

CMCT understands that the Commission will consider this request as confirmation by CMCT of its awareness of its responsibilities under the federal securities laws as they relate to the proposed public offering of the securities covered by the Registration Statement.

 

CMCT requests that the Commission notify us of the effectiveness of the Registration Statement by calling our counsel, Patrick S. Brown of Sullivan & Cromwell LLP, at (310) 712-6603.

 

 

Sincerely,

 

 

 

/s/ David Thompson

 

David Thompson

 

Chief Financial Officer

 

cc:                                Joshua Lobert

(Securities and Exchange Commission)

 

Patrick S. Brown

(Sullivan & Cromwell LLP)

 

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