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March 5, 2024
Sachin Latawa
Chief Executive Officer
Tirios Propco Series LLC
8 The Green A
Dover, DE 19901
Re:Tirios Propco Series LLC
Amendment No. 7 to Offering Statement on Form 1-A
Filed February 8, 2024
File No. 024-12277
Dear Sachin Latawa:
            We have reviewed your amended 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. Unless we note otherwise,
any references to prior comments are to comments in our January 2, 2024, letter.
Amendment 7 to Offering Statement on Form 1-A
Risk Factors
Risks Related to this Offering and Ownership of our Series Interests
If either the Manager or Company is required to register as a broker-dealer, page 16
1.You state here that “[t]he Company and Manager are relying on exemptions from the
definition of “Broker” and “Dealer” for the sale of Series Interests and operation of the
Secondary Trading Platform.” Please clarify what exemptions you are referring to.
Procedure for Transfer on Tirios Secondary Platform, page 34
2.We note your revised disclosure in the second paragraph of section 8 on page 35 in
response to comment 8. Please correct the page number in your added cross-reference to
the section headed, “Securities being offered – General Restrictions on Transfer."

 FirstName LastNameSachin  Latawa
 Comapany NameTirios Propco Series LLC
 March 5, 2024 Page 2
 FirstName LastNameSachin  Latawa
Tirios Propco Series LLC
March 5, 2024
Page 2
3.We note your Section 15(a) analysis in response to comments 4 and 6. Notwithstanding
your assertion that the Company and the Manager will not receive transaction-based
compensation, please provide a detailed legal analysis as to why you believe the Company
and/or the Manager would not be a “broker” or “dealer” under the Exchange Act as a
result of their operation of the Tirios Secondary Platform. In your response, please cite to
applicable case law, no-action letters, or other guidance. In addition, please clarify and
address at least the following:
•Whether customers open accounts with Dalmore;
•Whether Dalmore maintains or handles customer funds or securities;
•Whether the Tirios Secondary Platform transmits customer orders directly to the
ATS;
•Whether customers submit their orders directly to Dalmore;
•Whether the Tirios Secondary Platform facilitates negotiations between customers;
and
•Whether the Company or Manager receives any compensation in connection with the
operation of the Tirios Secondary Platform.
4.Please provide a detailed description of the operation of the Tirios Secondary Platform
and the lifecycle of a secondary transaction on the platform.
Independent Audit's Report, page FS-2
5.Please have your independent auditor explain to us how it determined not to issue a going
concern opinion on the financial statements given the company's lack of an operating
history, accumulated losses to date and its dependency on financing to continue its
business. We note the disclosure in Note 8 that discusses financial and other
uncertainties. The assurances that the company can continue to generate cash flow from
rental properties, raise capital through a Regulation A offering or that the Manager will
always be in a position to provide funding when needed appear ambiguous and not
determinative of the company's ability to continue as a going concern. Please advise or
revise.
Exhibits
6.We note that you have entered into rental agreements for the 283 Gabbro Gardens and 313
Mica Trail properties. Please file the executed rental agreements as exhibits, rather than
the form of the agreement.

 FirstName LastNameSachin  Latawa
 Comapany NameTirios Propco Series LLC
 March 5, 2024 Page 3
 FirstName LastName
Sachin  Latawa
Tirios Propco Series LLC
March 5, 2024
Page 3
            Please contact Paul Cline at 202-551-3851 or Shannon Menjivar at 202-551-3856 if you
have questions regarding comments on the financial statements and related matters. Please
contact Stacie Gorman at 202-551-3585 or Pam Howell at 202-551-3357 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction
cc:       Arden Anderson, Esq.