SecProbe.io

CORRESP
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    Division of Corporation Finance
    Via Edgar

    Office of Real Estate & Construction

    U.S. Securities & Exchange Commission

    100 F Street, NE

    Washington, D.C. 20549

October 24, 2024

Re: Concreit Fund I LLC

Offering Statement on Form
1-A

Filed July 2, 2024

File No. 024-12457

Dear Sir or Madam:

This letter is submitted on
behalf of Concreit Fund I LLC (the “Company”) in response to comments from the staff of the Division of Corporation Finance,
Office of Real Estate & Construction (the “Staff”) of the Securities & Exchange Commission (the “Commission”)
in a letter dated August 2, 2024 (the “Comment Letter”) with respect to the Company’s Offering Statement on Form 1-A
(File No. 024-12457) submitted for review pursuant to Regulation A under the Securities Act of 1933, as filed, to the Commission on July
2, 2024. The responses provided are based upon information provided by the Company. Each line item below corresponds to the comment number
in your letter followed by our response:

Offering Statement on Form
1-A

 i. General.

1.            Comment:
We note your disclosure on page 85 that “[s]ettlement may occur up to 60 days after a prospective investor submits a subscription
agreement.” Please tell us how your offering complies with the prohibition in Rule 251(d)(3) against delayed offerings.

Response: Regarding
your comment on our disclosure that “[s]ettlement may occur up to 60 days after a prospective investor submits a subscription agreement,”
we have removed this sentence entirely from our Offering Circular to ensure compliance with Rule 251(d)(3) of Regulation A. This rule
prohibits delayed offerings, and we understand that our previous disclosure could be interpreted as suggesting a delayed offering structure.

To clarify, we have been
and intend to conduct our offering on a best-efforts basis, with settlement occurring promptly after the sale of Investor Shares. We have
revised our Offering Circular to remove any language that could be construed as indicating a delayed offering. Specifically, we have removed
the sentence in question from page 85 of our Offering Circular.

We believe that this revision
addresses your concern and ensures that our offering complies with the requirements of Rule 251(d)(3). We are committed to transparency
and compliance with all applicable regulations.

2.            Comment:
Please revise your risk factors section to disclose that the investors will have voting rights only with respect to certain matters, primarily
relating to amendments to your Operating Agreement that would adversely change the rights of the Investor Shares, and the removal of Manager
for “cause”.

Response: Please
be advised that the request has been completed by adding a Voting Rights disclosure under the risk factors.

3.            Comment:
Please revise to disclose your historical NAV information. Furthermore, please confirm that you will disclose NAV information in your
future semi-annual and annual reports.

Re:
Response Letter

October 24, 2024

 Page 2

Response: Please
be advised that the request has been completed and that Historical NAV Information has been disclosed. We have, and will continue to disclose
NAV information in our future semi-annual and annual reports.

4.            Comment:
We note your response to Item 4 in Part I that you have raised $3,815,533.00 in sales of securities in qualified offering statements within
the prior 12 months. Please revise your response to Item 6 in Part I to also address those sales of investor shares.

Response: Please
be advised that the request has been completed.

5.            Comment:
We note your disclosure that as of May 31, 2024, you have issued and sold 13,542,002 investor Shares in the amount of $12,999,115. We
also note that you filed a 1-A POS on May 7, 2021, which was qualified on May 13, 2021. Additionally, we note your Form 1-K for the fiscal
year ended December 31, 2023, indicates that the proceeds from the sale of investor shares were $4,847,603 in 2023 and $4,408,013 in 2022.
We also note your Form 1-K for the fiscal year ended December 31, 2022, indicates that the proceeds for the sales of investor shares was
$2,687,237 in 2021. Please advise us of all the sales of Investor Shares made from May 13, 2021, through July 2, 2024, and clarify whether
the sales were made under Regulation A, Regulation D, or other exemptions. Please advise us of the exemption(s) relied upon for those
sales and how you have complied with each exemption. Please also tell us what information was provided to these investors in connection
with their purchases.

Response: The
table below represents all of the sales of Investor Shares between May 13, 2021 and July 2, 2024:

Exemption
Shares Sold
Amount in Dollars

Regulation A+ Tier 2
13,087,343
$12,563,849

Regulation D 506(c)
771,408
$740,551

We relied on the Regulation
A+ Tier 2 exemption for the sale of 13,087,343 shares. Our offering statement on Form 1-A was qualified by the SEC on May 13, 2021. We
complied with all requirements under Regulation A+, including providing investors with access to our offering circular and ensuring that
all sales were conducted in accordance with the terms outlined in our qualified offering statement.

For the sale of 771,408 shares,
we relied on Regulation D Rule 506(c), which allows for general solicitation provided that all purchasers are accredited investors. We
verified the accredited status of each investor and provided them with a private placement memorandum outlining the terms and risks associated
with their investment.

All sales were facilitated
through our mobile app or web app where investors have access to comprehensive information about the corresponding offering or private
placement. More specifically we provided:

 ● Offering Circular (for Regulation A+ Tier 2): This document included detailed information about our company,
investment strategy, financial statements, and terms of the offering.

 ● Private Placement Memorandum (for Regulation D 506(c)): This document outlined the specific terms and
conditions of the investment, including risk factors and investor rights.

 ● Subscription Agreement: Investors were required to review and execute a subscription agreement as part
of their investment process.

 ii. Cover page.

6.            Comment:
We note the top right of your cover page states that this is the “Offering Circular Amendment No. 2 dated June 25, 2024.”
Please revise, here and elsewhere, to reflect that this is an offering statement on Form 1-A filed on July 2, 2024.

Re:
Response Letter

October 24, 2024

 Page 3

Response: Please
be advised that the request has been completed and revised.

7.            Comment:
It appears you are attempting to conduct an at the market offering which is not permitted under Rule 251(d)(3)(ii) of Regulation A. Please
revise or advise.

Response: Our
offering is not intended to be an at-the-market offering as defined in Rule 251(d)(3)(ii). We understand that at-the-market offerings
involve selling securities into an existing trading market for outstanding shares of the same class at other than a fixed price. Our offering
is structured as a best-efforts offering with a fixed price per Investor Share, which is adjusted at the beginning of every fiscal month
based on our net asset value (NAV) as of the end of the prior fiscal month.

	To ensure compliance with Regulation A, we have reviewed and revised our Offering Circular to remove any language that could be interpreted
as suggesting an at-the-market offering structure. Specifically, we have removed any references to selling securities at variable prices
or into an existing trading market.

8.            Comment:
We note your disclosure that as of May 31, 2024, you have issued and sold 13,542,002 Investor Shares through a registered broker-dealer,
in the amount of $12,999,115. Please advise us of the amount of Investor Shares that have been sold within the past 12 months in your
Regulation A offering. In this regard, we note your disclosure on page 50 that “[s]ubsequent to December 31, 2023, the Fund has
approximately raised an additional $1,053,289.” We also note your response to Item 4 in Part I that you have raised $3,815,533.00
in sales from qualified offering statements within the prior 12 months. Revise your total offering amount of “up to $75,000,000
in Investor Shares” to reflect your prior sales of investor shares sold pursuant to other offering statements within the 12 months
before the start of the current offering. See Securities Act Rule 251(a)(2).

Response: In
the past 12 months, we have sold 3,974,514 shares for $3,815,533 through this Regulation A offering. In regards to the referenced disclosure
on page 50, this was duplicated from our 2023 financial statements therefore we have removed this disclosure.

We have revised the total
offering amount to reflect our prior sales of investors shares sold pursuant to other offering statements within the 12 months before
the start of the current offering.

9.             Comment:
Please revise your cover page to indicate that the offering will terminate three years from the qualification date of the offering. See
Rule 251(d)(3)(i)(F).

Response: Please
be advised that the requested revisions have been completed and have indicated that the offering will terminate three years from the qualification
date of the offering.

10.          Comment:
We note your disclosure that you “intend to qualify” as a REIT for U.S. federal income tax purposes. However, your disclosure
on pages 62 and 64 seem to indicate that you intended to qualify as a REIT beginning with the “taxable year ended December 31, 2022.”
Please revise to clarify whether you have yet elected to be taxed as a REIT. Also revise to update your disclosures through out the offering
statement to reflect the company’s current operations and current status as applicable.

Response: Please
be advised that the requested revisions have been completed as we intend to elect to be taxed as a REIT beginning with the taxable year
ending December 31, 2024.

11.          Comment:
We note your statement that you have a “limited operating history.” However, it appears that you have been operating for several
years. In this regard, we note that you were formed on May 24, 2019 and your initial 1-A was qualified on May 21, 2020. Please update
your offering statement to address these events and other important events as appropriate.

Response: Please
be advised that the requested change has been made.

12.          Comment:
We note that you have included “Proceeds from the Private Placement to Accredited Investors under Regulation D” and “Proceeds
to Us from the Private Placement to our Sponsor” in your offering table. We do not understand why you have included these proceeds
in your offering table since the offering statement does not cover your Regulation D private placement offering nor your private placement
to your Sponsor. Please remove both of the private placement proceeds from your offering table on the cover page.

Re:
Response Letter

October 24, 2024

 Page 4

Response: Please
be advised that the requested revisions have been completed and we have removed the sections referring to the private placement referenced.

 iii. Table of Contents, page i.

13.          Comment:
Please revise to include the page numbers and the hyperlinks to “Properties and Securities” and “Direct Reinvestment
Plan” sections.

Response: Please
be advised that the request has been completed and we have revised and added “Mortgages, Properties and Investments” and “Distribution
Reinvestment Plan” to our Table of Contents with corresponding page numbers and hyperlinks.

 iv. Summary, page 1.

14.          Comment:
Please revise your disclosure that you are a “recently organized” Delaware limited liability company. Given your disclosure
on page F-8 that you were formed on May 24, 2019, it appears that you were formed more than five years ago. Revise to indicate the date
Concreit Fund I LLC was formed.

Response: Please
be advised that the requested revision has been completed and we have revised the section referenced to indicate the date Concreit Fund
I LLC was formed.

 v. Our Organizational Structure, page 3.

15.          Comment:
Please revise your organizational structure chart so that the texts are clearly legible.

Response: Please
be advised that the request has been completed.

 vi. Management Compensation, page 4.

16.          Comment:
To the extent that any management compensation has been awarded, earned or paid, please revise your tables, here and on page 35, to disclose
the amounts of management compensation. For example, please indicate the amounts of organization and offering expenses paid by the Manager
and the amounts reimbursed to the Manager. We also note that the company has made four private equity investments and sixteen debt investments
as noted in the Investments section on page 29. It appears to us that the noted fees in the Management Compensation section, on page 35,
have either been awarded to, earned by, or paid to the Manager in connection with those noted investments. See Item 22 of Form S-11 and
Item 402 of Regulation S-K.

Response: Please
be advised that the request has been completed and we have disclosed the amounts as of June 30, 2024.

 vii. Related Fees Paid by Unaffiliated Third Parties, page 6.

17.          Comment:
We note that you were formed more than five years ago on May 24, 2019. Please disclose, here and on page 38, the amounts of any related
fees paid by unaffiliated third parties to your manager as of the date of this offering statement. If no related fees paid by unaffiliated
third parties have been paid up to the date of the offering statement, then clearly indicate that in this section.

Response: Please
be advised that the request has been completed and we have included related fees paid by unaffiliated third parties to our manager.

 viii. Distributions, page 7.

18.          Comment:
Please revise to clarify when you intend to make the election to be taxed as a REIT.

Response: Please
be advised that the request has been completed and we have disclosed when we intend to make the election to be taxed as a REIT.

Re:
Response Letter

October 24, 2024

 Page 5

 ix. Valuation and Net Asset Value (NAV) Policies, page 8.

19.          Comment:
We note your disclosure that your $0.96 price per share is based on your current net asset value. Please revise your offering circular
to include a quantitative valuation breakdown (e.g., fair value of equity investments, fair value of loans and participations held for
investment), or tell us how you determined such disclosure is not necessary.

Response: Please
be advised that the request has been completed and we have included a quantitative valuation breakdown.

20.          Comment:
Please provide us, on a supplemental basis, with your template for future NAV disclosures.

Response: We
have, and plan to continue to provide future NAV disclosures by submitting 253(g)(2) filings and on a monthly basis.

 x. Risk Factors

The Company and its Manager
are newly formed entities …, page 11

21.          Comment:
We note your disclosure that both you and your manager were formed on May 24, 2019. Since it has been more than five years since their
formations, please revise your disclosure that the company and your manager are “newly formed entities with no operating history.”

Response: Please
be advised that the request has been completed.

By purchasing Investor
Shares in this Offering, you are bound by the jury trial waiver provisions …, page 13

22.          Comment:
We note that your Operating Agreement and Subscription Agreement contain jury trial waiver provisions. Please revise to clearly disclose:

 ● the risks of the provision or other impacts on shareholders, such as the increased costs to bring a claim,
limited access to inform