SecProbe.io

March 30, 2020
Jeffrey Taylor
Managing Director
Black Creek Diversified Property Fund Inc.
518 Seventeenth Street, 17th Floor
Denver, CO 80202
Re:Black Creek Diversified Property Fund Inc.
Post-Effective Amendment to Form S-11
Filed March 19, 2020
File No. 333-222630
Dear Mr. Taylor:
            We have reviewed your post-effective amendment and have the following comment.  In
our comment, we may ask you to provide us with information so we may better understand your
disclosure.
            Please respond to this letter by amending your registration statement and providing the
requested information.  If you do not believe our comment applies to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
            After reviewing any amendment to your registration statement and the information you
provide in response to this comment, we may have additional comments.
Post-Effective Amendment No. 21 to Registration Statement on Form S-11 filed March 19, 2020
Forum for Certain Litigation, page 213
1.We note that your forum selection provision identifies the Circuit Court for Baltimore
City, Maryland as the exclusive forum for certain litigation, including any “derivative
action.”  Please disclose whether this provision applies to actions arising under the
Securities Act or Exchange Act.  In that regard, we note that Section 27 of the Exchange
Act creates exclusive federal jurisdiction over all suits brought to enforce any duty or
liability created by the Exchange Act or the rules and regulations thereunder, and Section
22 of the Securities Act creates concurrent jurisdiction for federal and state courts over all
suits brought to enforce any duty or liability created by the Securities Act or the rules and
regulations thereunder.  If the provision applies to Securities Act claims, please also revise
your prospectus to state that there is uncertainty as to whether a court would enforce such

 FirstName LastNameJeffrey Taylor
 Comapany NameBlack Creek Diversified Property Fund Inc.
 March 30, 2020 Page 2
 FirstName LastName
Jeffrey Taylor
Black Creek Diversified Property Fund Inc.
March 30, 2020
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provision and that investors cannot waive compliance with the federal securities laws and
the rules and regulations thereunder.
            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.
            You may contact Jonathan Burr at 202-551-5833 or James Lopez at 202-551-3536 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction