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        ATTORNEYS
        AT LAW

        100
        North Tampa Street, Suite 2700

        Tampa, FL 33602-5810

        P.O. Box 3391

        Tampa,
        FL 33601-3391

        858.847.6833
        TEL

        813.221.4210
        FAX

        www.foley.com

November 1, 2016

Via E-Mail

        Ms. Folake Ayoola

        Senior Counsel

        Office of Real Estate and Commodities

        Division of Corporation Finance

        U.S. Securities & Exchange Commission

        100 F Street, NE

        Washington, D.C. 20549

 Re: Innovative Industrial Properties, Inc.

Registration Statement on Form S-11

File No. 333-214148

Dear Ms. Ayoola:

As you, Jennifer Gowetski and I discussed
earlier today, I am providing to you under cover of this letter additional information regarding the position of Innovative Industrial
Properties, Inc. (the “Company”) that neither the Company’s Executive Chairman, Alan D. Gold, nor the
Company’s Vice Chairman of the Board of Directors, Gary A. Kreitzer is the sponsor of a prior “program” pursuant
to guidance of the Securities and Exchange Commission (the “Commission”) regarding Industry Guide 5 (“Guide
5”) and, therefore, not subject to the disclosure requirements of Guide 5 with respect thereto. Included below is additional
information regarding Mr. Gold’s and Mr. Kreitzer’s previous positions, which we believe will assist the staff of the
Division of Corporation Finance of the Commission in its analysis as to whether the disclosure already included in the above-referenced
registration statement (the “Registration Statement”) is sufficient for purposes of Guide 5 with respect to
the previous positions of Messrs. Gold and Kreitzer.

The Company continues to believe that prior
performance information called for by Item 8 of Guide 5 is not relevant to the Company for the reasons noted below. Item 8 calls
for “a narrative summary of the ‘track record’ or prior performance of programs sponsored by the
general partner and its affiliates (‘sponsors’).” Although not defined in Guide 5, in the Commission’s
releases that accompanied the adoption of, and revisions to, Guide 5 (which was originally adopted as Guide 60), the Commission
has discussed what it meant by the term “program” as used in Guide 5. In Release No. 34-18161 (October 7, 1981), the
Commission makes clear that a “program” is a three-phase investment fund or a syndication involving (i) an offering
or organization phase in which “the sponsor (who also serves as promoter and, later, general partner) organizes and registers
the offering;” (ii) a second “operational phase of the program [which] commences with the acquisition of properties;”
and (iii) a third phase in which “depending on the investment objectives of the program, the program is ‘completed’
as the partnerships are liquidated and wound down.”

    Boston

        Brussels

        CHICAGO

        Detroit

    JACKSONVILLE

        LOS
        ANGELES

        MADISON

        MIAMI

    MILWAUKEE

        NEW
        YORK

        ORLANDO

        SACRAMENTO

    SAN
        DIEGO

        SAN
        FRANCISCO

        SHANGHAI

        SILICON
        VALLEY

    TALLAHASSEE

        TAMPA

        TOKYO

        WASHINGTON,
        D.C.

Ms. Folake Ayoola

November 1, 2016

Page 2

BioMed Realty Trust, Inc. (“BioMed”),
a REIT focused on acquiring, developing, owning, leasing and managing laboratory and office space for the life science industry,
was founded in 2004 by the Company’s Executive Chairman, Alan D. Gold and the Company’s Vice Chairman of the Board
of Directors, Gary A. Kreitzer. Mr. Gold served as Chairman, Chief Executive Officer, and President of BioMed from 2004 through
2016. Mr. Kreitzer currently serves as BioMed’s Executive Vice President, a position he has held since 2004.

Prior to 2016, BioMed was a publicly-traded,
internally-managed, perpetual-life REIT that had a multi-employee management team and an independent board of directors that oversaw
and directed its operations, including its investment and financing activities. BioMed was acquired by a private buyer in 2016,
continues to actively conduct its business and has not entered into anything akin to a “wind-down” phase. The sale
of BioMed was as a going concern without the liquidation of any material assets.

Alexandria Real Estate Equities, Inc. (“Alexandria”)
is a New York Stock Exchange-listed urban office REIT focused on collaborative science and technology campuses. Mr. Gold served
as President (reporting to the company’s chief executive officer) and a director of Alexandria from 1994 to 1998. Mr. Kreitzer
served as Senior Vice President and In-House Counsel of Alexandria from 1994 to 1998. Alexandria is a publicly-traded, internally-managed,
perpetual-life REIT that has a multi-employee management team and an independent board of directors that oversees and directs its
operations, including its investment and financing activities. Alexandria continues to exist as a perpetual-life New York Stock
Exchange-listed REIT, despite the resignations of Messrs. Gold and Kreitzer in 1998.

The Company continues to believe that none
of its executive officers has sponsored a “program.” Messrs. Gold and Kreitzer served as only part of the multi-employee
management teams of BioMed and Alexandria, and in that capacity, they reported to senior members of the management teams and the
boards of directors of those companies. Furthermore, Messrs. Gold and Kreitzer did not constitute a majority of the members of
the multi-employee management teams or the board of directors of either company. Accordingly, in contrast to the principals of
a general partner of a limited partnership (or a manager of a limited liability company), Messrs. Gold and Kreitzer did not possess
the ultimate decision making authority for either BioMed or Alexandria. Their decision making authority and level of control was
no greater than any other corporate officer or employee-director in a company managed by a multi-employee management team and a
board of directors composed of a majority of independent directors.

With respect to the Company, Mr. Gold serves
as one member of a multi-employee management team of the Company. Mr. Kreitzer is not a member of the Company’s management
team. Furthermore, when the offering is declared effective, Messrs. Gold and Kreitzer will not constitute a majority of the members
of the Company’s board of directors.

Ms. Folake Ayoola

November 1, 2016

Page 3

Since Messrs. Gold and Kreitzer did not
control the sale or other disposition of the real estate assets of either BioMed or Alexandria, and because BioMed was sold with
its portfolio largely intact, there was no investment “program” for which track record information could be provided.

For the foregoing reasons, the Company believes
that neither BioMed nor Alexandria constitutes a program sponsored by Messrs. Gold or Kreitzer within the meaning of Guide 5. In
addition, the involvement of Messrs. Gold and Kreitzer with Alexandria is outside of the ten-year period specified by Item 8(A)
of Guide 5.

The Company has included in the Registration
Statement the disclosure required by Guide 5 to the extent that the Company believes that such disclosure is applicable, appropriate
and would be helpful to potential investors, while avoiding disclosure that would be potentially confusing or misleading to investors
(i.e. many of the Guide 5 disclosures do not apply to an internally-managed REIT). The Company continues to believe that
it has met the standard articulated in Release No. 33-6900 to provide investors with “clear, concise and understandable disclosure
of material information” about the offering.

	We look forward to working with you to finalize the disclosure
in the Company’s Registration Statement.

    Very truly yours,

    /s/ Carolyn T. Long

    Carolyn T. Long