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CORRESP
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  Troutman Pepper Hamilton Sanders LLP

600 Peachtree Street NE, Suite 3000

Atlanta, GA 30308-2216

troutman.com

Mary Katherine Rawls

marykatherine.rawls@troutman.com

March 7, 2023

William Demarest

Isaac Esquivel

Division of Corporation Finance

Office of Real Estate & Construction

United States Securities and Exchange
Commission

Washington, D.C. 20549

Re: Procaccianti Hotel REIT, Inc.

  Form 10-K for fiscal year ended December 31, 2021

  Filed March 25, 2022

  Form 8-K filed June 27, 2022

  File Nos. 000-56272

Dear Messrs. Demarest and Esquivel:

Procaccianti Hotel REIT, Inc.,
a Maryland corporation (the “Company”), wishes to respond to the letter of the Division of Corporation Finance (the “Staff”)
of the United States Securities and Exchange Commission (the “Commission”) dated February 9, 2023. The headings and
numbered paragraphs below correspond to the headings and numbered paragraphs in the Staff’s comment letter. The Company hereby
responds to the specific comment as follows:

Form 8-K filed June 27, 2022

Item 8.01 Other Events

Determination of Estimated Per Share
NAVs, page 1

1.            We
note your response to prior comment 1. In addition to describing the impact of the liquidation preferences on K Shares, K-I Shares and
K-T Shares and subordination of fees payable to the Company’s advisor on your Estimated Per Share NAV calculation, please further
enhance your disclosure by providing quantitative information necessary to clearly understand your Estimated Per Share NAV calculation.
Please provide us with your Estimated Per Share NAV calculation for each class as of March 31, 2022 in your response.

March 7, 2023

Page 2

In addition to
the Company’s undertaking in its January 25, 2023 response letter to the Commission’s December 20, 2022 comment
letter (“Response No. 1”), the Company undertakes to expand its disclosure in subsequent filings to provide the quantitative
breakdown of the Estimated Per Share NAV calculation for each of its share classes in the format below. The following charts show the
components of the Estimated Per Share NAV as of March 31, 2022, in the aggregate and by share class:

    Components of NAV
    3/31/2022

    Real Estate
    $ 130,270,000

    Mortgage Notes Payable
      (63,343,282 )

    Other Assets
      10,455,970

    Other Liabilities
      (4,181,996 )

    Noncontrolling Interest
      (9,052,965 )

    Net Asset Value
    $ 64,147,727

    Components of NAV by Share Class
    K-I
    K
    K-T
    Class A
    Class B
    Total

    Accrued Unpaid Distributions
    $ 230,087
    $ 708,266
    $ 11,017
    $ 1,473,071
    $ 0
    $ 2,422,441

    Liquidation Preference
      13,219,139
      40,811,110
      631,997
      5,814,095
      0
      60,476,341

    Remaining Distribution Allocation
      151,018
      466,234
      7,220
      468,354
      156,118
      1,248,944

    Net Asset Value
      13,600,244
      41,985,611
      650,234
      7,755,521
      156,118
    $ 64,147,727

    Shares Outstanding
      1,321,914
      4,081,111
      63,200
      581,410
      125,000

    NAV Per Share
    $ 10.29
    $ 10.29
    $ 10.29
    $ 13.34
    $ 1.25

The
Estimated Per Share NAV was calculated in accordance with our Charter, as amended, taking into account (i) first, the liquidation preference
on the K-I Shares, K Shares and K-T Shares equal to $10.00, plus all accumulated, accrued, and unpaid distributions on our K-I Shares,
K Shares and K-T Shares, respectively; (ii) second, the payment of any deferred and unpaid asset management fees, acquisition fees and
disposition fees (including interest accrued on all such fees at a non-compounded rate of 6.0% per annum) to our advisor; (iii) third,
the liquidation preference on the A Shares equal to $10.00, plus all accumulated, accrued and unpaid distributions on our A Shares; and
(iv)  finally, following the distribution and payment in full of all of the preceding obligations, (a) 50.0% of all remaining
NAV allocated to the holders of the K-I Shares, K Shares, K-T Shares (pro rata based on the number of K-I Shares, K Shares, and K-T Shares);
(b) 12.5% of remaining NAV to the B Shares; and (c) 37.5% of remaining NAV to the A Shares.

The Company believes that
the information below, together with the information provided in Response No. 1 and the Company’s current disclosures, clearly
describe the calculation of the Company’s Estimated Per Share NAV.

If you have any questions
or comments please contact me at (678) 592 -7738.

Best regards,

Mary Katherine Rawls

Cc: Heath D. Linsky

Gregory Vickowski

Ron Hadar