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December 5, 2023
Gerald Ellenburg
Chief Executive Officer
ERC Communities 1, Inc.
650 East Bloomingdale Avenue
Brandon, FL 33511
Re:ERC Communities 1, Inc.
Offering Statement on Form 1-A
Filed November 8, 2023
File No. 024-12355
Dear Gerald Ellenburg:
            We have reviewed your offering statement and have the following comments.
            Please respond to this letter by amending your offering statement and providing the
requested information. If you do not believe a comment applies to your facts and circumstances
or do not believe an amendment is appropriate, please tell us why in your response. After
reviewing any amendment to your offering statement and the information you provide in
response to this letter, we may have additional comments.
Offering Statement on Form 1-A filed November 8, 2023
General
1.Please revise to reconcile your disclosure regarding the management fee, which states that
the monthly management fee is 3.0% of assets under development, with the management
services agreement, which states that the monthly management fee is the greater of
$80,000 or 3.0% of gross revenue.
2.To the extent you are no longer offering shares of your Class A Preferred Stock, please
revise the disclosure on your website located at https://erccommunities.com to clearly
distinguish between the offering of your Class A Preferred Stock and this offering. As
non-exclusive examples only, we note disclosure on your website regarding a 10% annual
dividend, paid quarterly, and a share price of $12.50. We also note the "INVEST NOW"
link, leading to a page that appears to be maintained by DealMaker, which page includes
(i) disclosure suggesting the company's offering has closed and (ii) a "Follow ERC
COMMUNITIES 1, INC." button leading to testing the waters materials that appear to be
related to the offering of your Class A Preferred Stock.

 FirstName LastNameGerald Ellenburg
 Comapany NameERC Communities 1, Inc.
 December 5, 2023 Page 2
 FirstName LastNameGerald Ellenburg
ERC Communities 1, Inc.
December 5, 2023
Page 2
Cover Page
3.Please revise to disclose that the offering price has been arbitrarily determined by the
company.
4.Please revise to disclose, if true, that the company does not currently intend to list its
Class A Common Stock for trading on a national securities exchange or to apply for
trading or quotation of its Class A Common Stock on an over-the-counter market, and
investors should therefore be prepared to hold their shares indefinitely.
5.We note your disclosure that the company may undertake one or more closings on a
rolling basis. As applicable, please revise to clarify when an initial closing will take place
and when any subsequent closing following such initial closing will take place. Please
also revise to indicate how long the company will take to accept or reject the subscription
agreements submitted by investors.

Additionally, please revise your Plan of Distribution section consistent with the revisions
to the cover page.
6.Please revise to indicate the number of votes each Class A Preferred Stock is entitled to.
Plan of Distribution, page 18
7.Please revise to specify the location of the blogs and other social media you will use to
provide notification of the Offering.
8.Please revise your disclosure to clarify that the offering may not extend beyond 3 years
from the initial qualification date. Also revise your cover page as appropriate. See Rule
251(d)(3)(i)(F).
Process of Subscribing, page 20
9.We note your reference to “selling stockholders” in this section. Please advise or revise as
appropriate.
The Company’s Business
Overview, page 23, page 23
10.Please revise your statistics table reflecting the three properties to include the interest rates
on the noted financings.
Conflicts of Interest, page 30
11.Please revise to disclose to what extent, if any, the involvement of each of Mr. Ellenburg
and Mr. Koenig with ERC Homes, LLC presents a conflict of interest with your business
and operations.

 FirstName LastNameGerald Ellenburg
 Comapany NameERC Communities 1, Inc.
 December 5, 2023 Page 3
 FirstName LastNameGerald Ellenburg
ERC Communities 1, Inc.
December 5, 2023
Page 3
Receipt of Fees and Other Compensation by ERC Parent and its Affiliates, page 30
12.Revise to address all the fees to ERC Parent and its affiliates that will be paid by the
company. Also address all the fees to ERC Parent and its affiliates in the Summary section
beginning on page 3.
Liquidity and Capital Resources, page 32
13.We note that the $1,200,000 note payable matured March 6, 2023 but is still reflected in
the company's consolidated balance sheet as of June 30, 2023. Please revise to disclose
whether ERC Zephyrhills, LLC exercised the two, six-month extensions, including any
extension fees paid; or whether the maturity date of the note was otherwise modified,
including any consideration given for such modification.
14.Please revise to disclose the interest rate and maturity date of the $367,000 note payable.
Directors, Executive Officers and Significant Employees, page 33
15.Please clarify whether David Morris III is an executive of the company. We note your risk
factor “ERC 1 depends on a small management team …”, on page 11, names David
Morris III as an executive of the company.
Security Ownership of Management and Certain Securityholders, page 35
16.Please revise to also address the group of all executive officers and directors as a group.
Interest of Management and Others in Certain Transactions, page 36
17.We note you indicate that ERC Parent and various of its shareholders have advanced
working capital to the company. Please revise to indicate the amounts advanced from
ERC Parent and each of its shareholders, who advanced working capital, during 2022 and
during 2023. Also clarify what these parties received when the advances were converted
into Additional Paid-in Capital in 2022 and 2023. Provide all the disclosure required by
Item 13(a) of Part II of Form 1-A for each transaction.
18.Please revise to address the amounts earned and/or paid to ERC Parent in 2021 and 2022
along with the current year pursuant to the management services agreement. See Item
13(a) of Part II of Form 1-A.
19.We note your statement that “some of the parties involved with the operation and
management of the company … have other relationships that may create disincentives to
act in the best interest of the company and its investors.” Please clarify if they have other
relationships beyond the involvement with GolfSuites and GolfSuites’s subsidiaries.
Forum Selection Provisions, page 39
20.Please revise to reconcile your disclosure regarding Section 6 of the subscription
agreement, which states that the Court of Chancery in the State of Delaware is the

 FirstName LastNameGerald Ellenburg
 Comapany NameERC Communities 1, Inc.
 December 5, 2023 Page 4
 FirstName LastName
Gerald Ellenburg
ERC Communities 1, Inc.
December 5, 2023
Page 4
exclusive forum, with the subscription agreement itself, which states that any state or
federal court located within the State of Delaware is the exclusive forum.
Independent Auditor's Report, page F-2
21.It appears that the license of your auditor may have expired on August 31, 2023. Please
confirm the status of the license and explain to us how the qualifications of your
independent accountant comply with Rule 2-01(a) of Regulation S-X, which requires that
a certified public accountant be registered and in good standing under the laws of the
place of their principal office. Refer to Part F/S(c)(iii) of Form 1-A.
            We will consider qualifying your offering statement at your request. If a participant in
your offering is required to clear its compensation arrangements with FINRA, please have
FINRA advise us that it has no objections to the compensation arrangements prior to
qualification.
            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. We also remind you that, following qualification of your Form 1-A, Rule 257
of Regulation A requires you to file periodic and current reports, including a Form 1-K which
will be due within 120 calendar days after the end of the fiscal year covered by the report.
            Please contact Eric McPhee at 202-551-3693 or Isaac Esquivel at 202-551-3395 if you
have questions regarding comments on the financial statements and related matters. Please
contact Benjamin Holt at 202-551-6614 or David Link at 202-551-3356 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction
cc:       Jamie Ostrow