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April 10, 2024
Matthew J. Fox
Chief Executive Officer
Benchmark Real Estate Investment Fund, LLC
3919 Remembrance Rd NW, Ste B
Grand Rapids, MI 49534
Re:Benchmark Real Estate Investment Fund, LLC
Offering Statement on Form 1-A
Filed March 15, 2024
File No. 024-12410
Dear Matthew J. Fox:
            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
General
1.We note that Article 19 of the operating agreement includes exclusive forum, mandatory
arbitration and waiver of jury trial provisions. Please disclose the material terms of these
provisions in your offering statement.  Clearly describe any risks or other impacts on
investors. Also, address their enforceability under applicable federal securities and
Delaware law.
2.We note your disclosure related to West Michigan Private Capital Fund I, LLC including
the disclosure regarding its business on page 23. Please provide the prior performance
disclosure required by section 8 of Industry Guide 5. In particular, please provide a prior
performance narrative and prior performance tables. Refer to Release No. 33-6900 (June
17, 1991), Item 7(c) of Part II of Form 1-A and CF Disclosure Guidance Topic No. 6.

 FirstName LastNameMatthew J.  Fox
 Comapany NameBenchmark Real Estate Investment Fund, LLC
 April 10, 2024 Page 2
 FirstName LastName
Matthew J.  Fox
Benchmark Real Estate Investment Fund, LLC
April 10, 2024
Page 2
            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 Ruairi Regan at 202-551-3269 or David Link at 202-551-3356 with any
other questions.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction
cc:       Nicholas Antaki, Esq.