SEC Company Response from Ares Real Estate Income Trust Inc. (ZARE) (CIK 0001327978) (ZARE) — Apr 28, 2022
Ares Real Estate Income Trust Inc. (ZARE) (CIK 0001327978)
Date: April 28, 2022 · CIK: 0001327978 · Accession: 0001104659-22-052238
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File numbers found in text: 333-252212
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CORRESP
1
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April 28, 2022
VIA EDGAR
Ms. Stacie Gorman
U.S. Securities and Exchange Commission
Division of Corporation Finance
100 F Street, NE, Mail Stop 3010
CF/AD8
Washington, DC 20549
Re: Ares Real Estate Income Trust Inc.
Registration Statement on Form S-11, as amended
File No. 333-252212
Ladies and Gentlemen:
In accordance with Rule 461 under
the Securities Act of 1933, Ares Real Estate Income Trust Inc. (the “Company”) hereby requests that the Securities
and Exchange Commission (the “Commission”) accelerate the effective date of the above-referenced Registration Statement in
order that the Registration Statement shall become effective at 9:00 A.M. (EDT) on May 3, 2022 or as soon thereafter as practicable.
In connection with the acceleration request, the Company hereby acknowledges
that:
· should the Commission or the staff, acting pursuant to delegated authority,
declare the Registration Statement effective, it does not foreclose the Commission from taking any action with respect to the Registration
Statement;
· the action of the Commission or the staff, acting pursuant to delegated authority,
in declaring the Registration Statement effective, does not relieve the Company from its full responsibility for the adequacy and accuracy
of the disclosure in the Registration Statement; and
· the Company may not assert this action as a defense in any proceeding initiated
by the Commission or any person under the federal securities laws of the United States.
Please contact Chris Stambaugh at 919-786-2040 of DLA Piper LLP (US),
counsel to the Company, with any questions about this acceleration request. Please notify us when the delegated authority copy of the
order of the Commission declaring the Registration Statement effective has been executed.
Very truly yours,
Ares Real Estate Income Trust Inc.
By:
/s/ Lainie P. Minnick
Name:
Lainie P. Minnick
Title:
Managing Director, Chief Financial Officer and Treasurer