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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

AI Filing Summary & Sentiment

File numbers found in text: 333-252212

Date
April 28, 2022
Author
Not clearly detected
Form
CORRESP
Company
Ares Real Estate Income Trust Inc. (ZARE) (CIK 0001327978)

Letter

Re: Ares Real Estate Income Trust Inc.

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

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.

Show Raw Text
CORRESP
1
filename1.htm

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