SecProbe.io

November 8, 2024
Tiffany Sy
Chief Financial Officer and Treasurer
Industrial Logistics Properties Trust
Two Newton Place
255 Washington Street
Suite 300
Newton, MA 02458-1634
Re:Industrial Logistics Properties Trust
Form 10-K for fiscal year ended December 31, 2023
Filed February 20, 2024
File No. 001-38342
Dear Tiffany Sy:
            We have limited our review of your filing to the financial statements and related
disclosures and have the following comment.
            Please respond to this letter within ten business days by providing the requested
information or advise us as soon as possible when you will respond. If you do not believe
the comment applies to your facts and circumstances, please tell us why in your response.
            After reviewing your response to this letter, we may have additional comments.
Form 10-K for fiscal year ended December 31, 2023
7. Management's Discussion and Analysis of Financial Condition and Results of Operations
Non-GAAP Financial Measures
Funds From Operations Attributable to Common Shareholders..., page 55
1.We note your disclosure of Per common share data pertaining to FFO attributable to
common shareholders and Normalized FFO attributable to common shareholders.  In
future periodic filings when presenting such per share measures, please present with
equal or greater prominence the most directly comparable financial
measure calculated and presented in accordance with US GAAP, which would appear
to be Net (loss) income attributable to common shareholders - diluted.  Refer to Item
10(e)(1)(i)(A) of Regulation S-K.

November 8, 2024
Page 2
            In closing, 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.
            Please contact Babette Cooper at 202-551-3396 or Mark Rakip at 202-551-3573 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction