SecProbe.io

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                                                          April 29, 2026

James R. Barry
Chief Financial Officer
SmartStop Self Storage REIT, Inc.
10 Terrace Road
Ladera Ranch, CA 92694

       Re: SmartStop Self Storage REIT, Inc.
           Form 10-K for the fiscal year ended December 31, 2025
           File No. 001-42584
Dear James R. Barry:

       We have completed our review of your filing. 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.

                                                          Sincerely,

                                                          Division of
Corporation Finance
                                                          Office of Real Estate
& Construction
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CORRESP
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   April 24, 2026   VIA EDGAR   Securities and Exchange Commission Division of Corporation Finance Office of Real Estate & Construction 100 F Street, N.E. Washington, D.C. 20549 Attn: Jeffrey Lewis; Isaac Esquivel

 Re:
 SmartStop Self Storage REIT, Inc.

 Form 10-K for the fiscal year ended December 31, 2025

 Form 8-K filed February 25, 2026

 File No. 001-42584

   Dear Gentlemen:   This letter is sent in response to your letter dated April 14, 2026, setting forth your comments to the review of the SmartStop Self Storage REIT, Inc.’s financial statements. We have reproduced your comments and included our responses below your comments. Form 10-K for the fiscal year ended December 31, 2025 Notes to Consolidated Financial Statements Note 6. Investments in Unconsolidated Real Estate Ventures, page F-31 1. Please tell us your consideration of providing financial statements pursuant to Rule 3-09 of Regulation S-X and summarized financial information pursuant to Rule 4-08(g) of Regulation S-X and ASC 323-10-50-3c for your equity method investments in unconsolidated real estate ventures and managed REITs. RESPONSE : In our consideration of providing financial statements or summarized financial information for our equity method investments in our unconsolidated real estate ventures and Managed REITs, we evaluated and performed the requisite calculations pursuant to Rule 3-09 of Regulation S-X (“Rule 3-09”) and Rule 4-08(g) of Regulation S-X (“Rule 4-08(g)”). With respect to the Investment Test and Income Test required by Rule 3-09, we determined that none of our equity method investments were in excess of the 20% thresholds. Therefore, separate financial statements of the equity method investees were not required. Similarly, with respect to the Investment Test, Asset Test and Income Test, in accordance with Rule 4-08(g), both individually and in the aggregate, we determined that we were not in excess of any of the 10% thresholds. Therefore, summarized financial information about our equity method investees was not required. The results of the Investment Test, Asset Test and Income Test (determined using the revenue criterion), as of and for the year ended December 31, 2025, as applicable, in the aggregate were approximately 6.9%, 5.4% and 3.3%, respectively. We also considered the disclosure requirement in ASC 323-10-50-3c. In addition to the results from the Investment Test, Asset Test and Income Test discussed above, we determined that the results reported in our Consolidated Statement of Operations under the line-items of “Equity in losses from investments in unconsolidated real estate ventures” and “Equity in losses from investments in Managed REITs”, were not quantitatively material, either individually or in the aggregate relative
 SmartStop Self Storage | 10 Terrace Road, Ladera Ranch, CA 92694 | 949.429.6600 | smartstop.com

 to our Consolidated Statement of Operations. Further, the carrying amount of investments in our investees common equity within the scope of ASC 323 represented approximately 1.8% of our total assets as of December 31, 2025, which we did not consider quantitatively significant. We also considered qualitative factors associated with our equity method investments, including that generally in our other disclosures there is a minimal level of discussion of our equity method investments and their impact on our financial condition and results of operations, which is consistent with the above quantitative considerations. Similarly, there were no other qualitative factors to otherwise conclude that our equity method investments were material in relation to our financial position or results of operations. Therefore, we concluded that the presentation of summarized financial information was not required in our Form 10-K.   Form 8-K filed February 25, 2026 Exhibit 99.1 Outlook for Full Year 2026, page 14 2. We note that you disclose full year 2026 guidance for non-GAAP measures, including Net operating income, Managed REIT EBITDA and Third-party platform adjusted EBITDA, without providing a reconciliation to the most directly related GAAP measure. In future filings, please include such reconciliation or, alternatively, provide a statement that the information could not be presented without unreasonable efforts under Item 10(e)(1)(i)(B) of Regulation S-K. Refer also to Questions 102.10(a) and 102.10(b) of the Corporation Finance Interpretations (“CFIs”) for Non-GAAP Financial Measures.   RESPONSE: We acknowledge the Staff’s comment and confirm that in future filings, we will provide such reconciliations or, alternatively, if applicable, provide a statement that the information could not be presented without unreasonable efforts under Item 10(e)(1)(i)(B) of Regulation S-K, as applicable. If you have any questions, or require additional information or documents, please contact the undersigned. Very truly yours,   SMARTSTOP SELF STORAGE REIT, INC.     By: /s/ James R. Barry James R. Barry Chief Financial Officer and Treasurer Phone: (949) 542-4513 Direct Email: jbarry@smartstop.com)   cc: H. Hirsch, Nelson Mullins Riley & Scarborough LLP N. Look, General Counsel and Secretary, SmartStop Self Storage REIT, Inc. Brent Horak, BDO USA, P.C.
 SmartStop Self Storage | 10 Terrace Road, Ladera Ranch, CA 92694 | 949.429.6600 | smartstop.com

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<TEXT>
 April 14, 2026

James R. Barry
Chief Financial Officer
SmartStop Self Storage REIT, Inc.
10 Terrace Road
Ladera Ranch, CA 92694

 Re: SmartStop Self Storage REIT, Inc.
 Form 10-K for the fiscal year ended December 31, 2025
 Form 8-K filed February 25, 2026
 File No. 001-42584
Dear James R. Barry:

 We have limited our review of your filing to the financial statements
and related
disclosures and have the following comments.

 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 a
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 the fiscal year ended December 31, 2025
Notes to Consolidated Financial Statements
Note 6. Investments in Unconsolidated Real Estate Ventures, page F-31

1. Please tell us your consideration of providing financial statements
pursuant to Rule 3-09
 of Regulation S-X and summarized financial information pursuant to Rule
4-08(g) of
 Regulation S-X and ASC 323-10-50-3c for your equity method investments
in
 unconsolidated real estate ventures and managed REITs.
Form 8-K filed February 25, 2026
Exhibit 99.1
Outlook for Full Year 2026, page 14

2. We note that you disclose full year 2026 guidance for non-GAAP measures,
including
 Net operating income, Managed REIT EBITDA and Third-party platform
adjusted
 EBITDA, without providing a reconciliation to the most directly related
GAAP measure.
 In future filings, please include such reconciliation or, alternatively,
provide a statement
 April 14, 2026
Page 2

 that the information could not be presented without unreasonable efforts
under Item
 10(e)(1)(i)(B) of Regulation S-K. Refer also to Questions 102.10(a) and
102.10(b) of the
 Corporation Finance Interpretations ("CFIs") for Non-GAAP Financial
Measures.
 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 Jeffrey Lewis at 202-551-6216 or Isaac Esquivel at
202-551-3395 with
any questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Real Estate
& Construction
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CORRESP
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 March 28, 2025
 Via EDGAR Office of Real Estate &
Construction U.S. Securities and Exchange Commission
 Division of Corporation Finance 100 F Street, N.E.
 Washington, D.C. 20549-3233 Attention: Ruairi Regan

 Re:

 SmartStop Self Storage REIT, Inc. Registration
Statement on Form S-11, as amended File
No. 333-264449

 Acceleration Request

     Requested Date: April 1, 2025

     Requested Time: 4:00 P.M. Eastern Time
 Pursuant to Rule 461 under the Securities Act of 1933, as amended (the “Act”), we hereby join in the request of
SmartStop Self Storage REIT, Inc. (the “Company”) that the effective date of the Company’s Registration Statement on Form S-11 (File No. 333-264449),
as amended, be accelerated to April 1, 2025 at 4:00 p.m. Eastern Time or as soon thereafter as practicable. The following is supplemental
information supplied under Rule 418(a)(7) and Rule 460 under the Act:

 (i)
 Dates of distribution: March 24, 2025 through the date hereof.
 (ii)   Pursuant to Rule 460 of the General Rules and Regulations of the Securities and Exchange Commission under the Act,
please be advised that there will be distributed to each underwriter or dealer, who is reasonably anticipated to participate in the distribution of the security, as many copies of the proposed form of preliminary prospectus as appears to be
reasonable to secure the adequate distribution of the preliminary prospectus.

 (iii)
 We have been informed by the participating underwriters that they have complied and will comply with the
requirements of Rule 15c2-8 under the Securities Exchange Act of 1934, as amended.
 [SIGNATURE PAGE FOLLOWS]
 Very truly yours,
 J.P. Morgan Securities LLC
 Wells Fargo Securities, LLC 
 KeyBanc Capital Markets Inc.
 BMO Capital Markets Corp.
 Truist Securities, Inc. 

 As Representatives of the Underwriters

 J.P. Morgan Securities LLC

 By:

 /s/ Samantha Carter

 Name: Samantha Carter

 Title: Vice President

 Wells Fargo Securities, LLC

 By:

 /s/ Rohit Mehta

 Name: Rohit Mehta

 Title: Managing Director

 KeyBanc Capital Markets Inc.

 By:

 /s/ Jaryd Banach

 Name: Jaryd Banach

 Title: Managing Director, Head of REGAL ECM

 BMO Capital Markets Corp.

 By:

 /s/ Eric Benedict

 Name: Eric Benedict

 Title: Co-Head, Global Equity Capital Markets

 Truist Securities, Inc.

 By:

 /s/ West Riggs

 Name: West Riggs

 Title: Managing Director

CORRESP
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 March 28, 2025
 VIA EDGAR U.S. Securities and Exchange
Commission Division of Corporation Finance 100 F Street,
N.E., Washington, D.C. 20549-3233

 Re:
 SmartStop Self Storage REIT, Inc.
 Registration Statement on Form S-11, as amended
 File No. 333-264449
 Ladies and Gentlemen: On behalf of SmartStop
Self Storage REIT, Inc. (the “Company”), and pursuant to Rule 461 promulgated under the Securities Act of 1933, as amended, the undersigned hereby requests that the effective date of the above referenced Registration Statement on Form S-11, as amended (the “Registration Statement”), be accelerated to April 1, 2025 at 4:00 pm Eastern Time, or as soon thereafter as practicable or at such later time as the Company or its counsel may
orally request via telephone call to the staff of the Division of Corporation Finance of the U.S. Securities and Exchange Commission. It
would be appreciated if, as soon as the Registration Statement is declared effective, you would inform Michael K. Rafter of Nelson Mullins Riley & Scarborough LLP, counsel to the Company, at
 (404) 322-6627.

 Very truly yours,

 SmartStop Self Storage REIT, Inc.

 By:

 /s/ H. Michael Schwartz

 H. Michael Schwartz

 Chief Executive Officer

 cc:
 Mr. James Barry
 Mr. Nicholas Look
 Mr. Michael K. Rafter, Nelson Mullins Riley & Scarborough LLP
 Mr. Julian T. H. Kleindorfer, Latham & Watkins LLP

United States securities and exchange commission logo
October 5, 2023
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
James R. Barry
Chief Financial Officer and Treasurer
SmartStop Self Storage REIT, Inc.
10 Terrace Road
Ladera Ranch, CA 92694
Re:SmartStop Self Storage REIT, Inc.
Registration Statement on Form S-11
Filed April 22, 2022
File No. 333-264449
Dear James R. Barry:
            It has been more than nine months since you last amended this registration statement and
it is now out of date. Within 30 days from the date of this letter, you should either:
•amend it to comply with the applicable requirements of the Securities Act of 1933, the rules
and regulations under the Act, and the requirements of the form; or
•file a request for withdrawal.

            If you requested confidential treatment for portions of any exhibits to your registration
statement and you request withdrawal of that registration statement, please submit a concurrent
request for withdrawal of your application for confidential treatment.
            If you do not amend the registration statement or file a request for withdrawal (or provide
us with a satisfactory explanation of why you have not done either) within 30 days, we may enter
an order declaring the registration statement abandoned under rule 479 of the Act.
            Please contact Joseph Ambrogi at 202-551-4821 or Ruairi Regan at 202-551-3269 with
any questions.

 FirstName LastNameJames R. Barry
 Comapany NameSmartStop Self Storage REIT, Inc.
 October 5, 2023 Page 2
 FirstName LastName
James R. Barry
SmartStop Self Storage REIT, Inc.
October 5, 2023
Page 2
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction

United States securities and exchange commission logo
May 3, 2022
James R. Barry
Chief Financial Officer and Treasurer
SmartStop Self Storage REIT, Inc.
10 Terrace Road
Ladera Ranch, CA 92694
Re:SmartStop Self Storage REIT, Inc.
Registration Statement on Form S-11
Filed April 22, 2022
File No. 333-264449
Dear Mr. Barry:
            This is to advise you that we have not reviewed and will not review your registration
statement.
            Please refer to Rules 460 and 461 regarding requests for acceleration.  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 Joseph Ambrogi at 202-551-4821 or Ruairi Regan at 202-551-3269 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction
cc:       Erin Reeves McGinnis, Esq.

CORRESP
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CORRESP

 April 14, 2022

VIA EDGAR

 Securities and Exchange Commission

 Division of Corporation Finance

 100 F Street, N.E., Mail
Stop 4561

 Washington, D.C. 20549

 Attention: Joe Ambrogi

Re:
 SmartStop Self Storage REIT, Inc.

Registration Statement on Form S-4

File No. 333-264087

Ladies and Gentlemen:

 In accordance with Rule
461 under the Securities Act of 1933, SmartStop Self Storage REIT, Inc. (the “Company”) hereby requests that the Securities and Exchange Commission (the “Commission”) accelerate the effective date of the above-captioned
Registration Statement in order that the Registration Statement shall become effective at 9:00 A.M. (ET) on April 18, 2022 or as soon thereafter as practicable.

Please contact Michael K. Rafter (404-322-6627) or Erin Reeves
McGinnis (404-322-6208) of Nelson Mullins Riley & Scarborough LLP, counsel to the Company, with any questions about this acceleration request. Please notify
either of the foregoing when this request for acceleration of effectiveness of the Registration Statement has been granted.

 Very truly yours,

 SmartStop Self Storage REIT, Inc.

By:

 /s/ H. Michael Schwartz

H. Michael Schwartz

Chief Executive Officer

United States securities and exchange commission logo
April 14, 2022
James R. Barry
Chief Financial Officer and Treasurer
SmartStop Self Storage REIT, Inc.
10 Terrace Road
Ladera Ranch, CA 92694
Re:SmartStop Self Storage REIT, Inc.
Registration Statement on Form S-4
Filed April 1, 2022
File No. 333-264087
Dear Mr. Barry:
            This is to advise you that we have not reviewed and will not review your registration
statement.
            Please refer to Rules 460 and 461 regarding requests for acceleration.  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 Joseph Ambrogi at 202-551-4821 or Ruairi Regan at 202-551-3269 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction
cc:       Erin Reeves McGinnis, Esq.

CORRESP
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SEC Acceleration Request

 January 7, 2021

VIA EDGAR TRANSMISSION

 Securities and Exchange
Commission

 Division of Corporation Finance

 100 F Street,
N.E.

 Washington, D.C. 20549

 Attention: Stacie Gorman

Re:
 SmartStop Self Storage REIT, Inc.

Registration Statement on Form S-4 (Registration
No. 333-251306)

 Ladies and Gentlemen:

In accordance with Rule 461 under the Securities Act of 1933, as amended, SmartStop Self Storage REIT, Inc. (the “Company”) hereby
requests that the Securities and Exchange Commission accelerate the effective date of the above-captioned Registration Statement in order that the Registration Statement shall become effective at 9:00 A.M. (ET) on January 11, 2021 or as soon
thereafter as practicable.

 Please contact Michael K. Rafter (404-322-6627) or Erin Reeves
McGinnis (404-322-6208) of Nelson Mullins Riley & Scarborough LLP, counsel to the Company, with any questions about this acceleration request. Please also
notify either of the foregoing when this request for acceleration of effectiveness of the Registration Statement has been granted.

Very truly yours,

SmartStop Self Storage REIT, Inc.

By:

 /s/ Michael McClure

Name:

Michael McClure

Title:

Chief Executive Officer

United States securities and exchange commission logo
December 18, 2020
Michael McClure
Chief Executive Officer
SmartStop Self Storage REIT, Inc.
10 Terrace Road
Ladera Ranch, CA 92694
Re:SmartStop Self Storage REIT, Inc.
Form S-4
Filed December 11, 2020
File No. 333-251306
Dear Mr. McClure:
            This is to advise you that we have not reviewed and will not review your registration
statement.
            Please refer to Rules 460 and 461 regarding requests for acceleration.  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 Stacie Gorman at 202-551-3585 with any questions.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction
cc:       Michael K. Rafter, Esq.

CORRESP
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CORRESP

 Nelson

Mullins

Nelson Mullins Riley & Scarborough LLP

Attorneys and Counselors at Law

Michael K. Rafter

Atlantic Station / 201 17th Street, NW / Suite 1700 / Atlanta, GA 30363

Tel: 404.322.6627

Tel: 404.322.6000 Fax: 404.322.6050

mike.rafter@nelsonmullins.com

www.nelsonmullins.com

 August 1, 2016

Via FedEx

 Mr. Coy Garrison

Special Counsel

 U.S. Securities and Exchange Commission

Division of Corporation Finance

 100 F Street, NE, Mail Stop 3233

 Washington, D.C. 20549

Re:
Strategic Storage Trust II, Inc.

 Post-Effective Amendment No. 11 to Form S-11

 Filed July 11, 2016

File No. 333-190983

 Dear Mr. Garrison:

 This letter is sent in response to your telephone conversations with Kara Davis on July 25, 2016 and July 28, 2016 setting forth your
comments to the Post-Effective Amendment for the Company’s offering. We have reproduced your comments and included our responses below your comments.

Distribution Declaration History, page 12 of the Cumulative Supplement dated July 11, 2016

1.
Please include a discussion of distributions paid and either earnings or Funds From Operations (FFO) for the period and cumulative since inception.

RESPONSE: In response to this comment, in the next supplement the Company files with the Securities and
Exchange Commission (SEC), the Company will include a discussion of distributions paid during the period compared to FFO and cumulative distributions paid since inception compared to cumulative FFO. We respectfully request that you clear this
comment.

 Related Party Fees and Expenses, page 3 of the Cumulative Supplement dated July 11, 2016

2.
Please revise your table of related party fees and expenses to include a line item for the stockholder servicing fee paid by stockholders of Class T shares.

RESPONSE: As mentioned during our telephone conversations, the stockholder servicing fee is not a line item
in the related party fees and expenses table because the fee is not currently material. In response to this comment, once the stockholder servicing fee is material, the Company will include this fee as a line item in the related party fees and
expenses table. We respectfully request that you clear this comment.

 August 1, 2016

 Page
 2

 The Company acknowledges that:

•

should the SEC or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the SEC from taking any action with respect to the filing;

•

the action of the SEC or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in
the filing; and

•

the Company may not assert staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the SEC or any person under the federal securities laws of the United States.

If you have any questions, or require additional information or documents, please contact the undersigned (404.322.6627;
mike.rafter@nelsonmullins.com) or Kara Davis (404.322.6679; kara.davis@nelsonmullins.com).

Very truly yours,

/s/ Michael K. Rafter

Michael K. Rafter

CORRESP
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CORRESP

 Nelson

Mullins

 Nelson Mullins Riley & Scarborough LLP

 Attorneys and Counselors at Law

Atlantic Station / 201 17th Street, NW / Suite 1700 / Atlanta, GA 30363

Tel: 404.322.6000 Fax: 404.322.6050

www.nelsonmullins.com

Michael K. Rafter
 Tel: 404.322.6627

mike.rafter@nelsonmullins.com

 September 24, 2015

Via FedEx

 Ms. Jennifer Gowetski

Special Counsel

 Office of Real Estate and Commodities

United States Securities and Exchange Commission

 Washington,
D.C. 20549

Re:
Strategic Storage Trust II, Inc.

Post-Effective Amendment to Form S-11

Filed August 27, 2015

File No. 333-190983

 Dear Ms. Gowetski:

This letter is sent in response to your letter dated September 3, 2015 setting forth your comments to the Post-Effective Amendment for
the Company’s offering. We have reproduced your comments and included our responses below your comments.

 Q: Why are you offering two classes of
your common stock, and what are the similarities and differences between the classes?, page 7

1.
Please revise to state how long a holder of a Class T share should expect to pay the stockholder servicing fee and the aggregate amount that a Class T holder should expect to pay before reaching the 10% cap.

 RESPONSE: In response to this comment, we have revised the disclosure on page 7 of our prospectus to include the
following statement: “A purchaser of Class T shares in our primary offering will pay $0.0079 per Class T Share per month (i.e. 1% divided by 12 months, then multiplied by the initial purchase price of $9.47 per share) in stockholder servicing
fees for each month from the date of purchase through the date we cease paying the stockholder servicing fee. Although we cannot predict the length of time over which this fee will be paid by any given investor due to, among many factors, the
varying dates of purchase and the timing of a liquidity event, we currently estimate that a Class T Share purchased immediately after the effective date of this prospectus will be subject to the stockholder servicing fee for 5 to 7 years and the
investor will pay aggregate fees of between $0.47 and $0.66 per share during that time.” We respectfully request that you clear this comment.

2.
You state on page 7 that the stockholder servicing fee paid in respect of Class T shares will be allocated to the Class T shares as a class expense, and these fees will impact the amount of distributions payable on all
Class T shares, including those purchased through your distribution reinvestment plan. We further note that you will not pay stockholder servicing fees with respect to shares sold pursuant to your distribution reinvestment plan. Please revise to
clarify how the stockholder servicing fee will impact the amount of distributions payable on the Class T shares purchased through the dividend reinvestment plan or advise.

 September 24, 2015

 Page
 2

 RESPONSE: The Class T shares sold pursuant to our distribution reinvestment will not
incur a stockholder servicing fee. We were attempting to make the point that, since all Class T shareholders bear the burden of paying the stockholder servicing fee as a class expense, all class T shares will be impacted, including shares purchased
pursuant to the distribution reinvestment plan (DRP), even though the stockholder servicing fee will not be paid on the DRP shares. However, in response to this comment and to avoid potential confusion, we have revised the disclosure on page 7 of
our prospectus to clarify: “The stockholder servicing fee paid in respect of Class T shares will be allocated to the Class T shares as a class expense, which will impact the amount of distributions payable on Class T shares.” We
respectfully request that you clear this comment.

3.
We note your disclosure on page 8 that, as a result of the allocation of the stockholder servicing fee to the Class T shares, the Class T shares could have a lower net asset value per share if distributions on the Class
T shares are not adjusted to take account of such fee. We further note the preceding sentence that distributions on the Class T shares will be lower than distributions on Class A shares because Class T shares are subject to the on-going
stockholder servicing fee. Please revise to clarify or describe the circumstances under which the distributions on the Class T shares would not be adjusted to take account of the stockholder servicing fee or advise. In addition, please tell us
whether the distribution amount on the Class T shares will increase once the 10% cap is reached.

 RESPONSE: In
response to this comment, we have revised the disclosure on page 8 of our prospectus to remove the sentence described in your comment and add the following sentence: “We expect the estimated net asset value per share of each Class A share
and Class T share to be the same, except in the unlikely event that the stockholder servicing fees exceed the amount otherwise available for distribution to holders of Class T shares in a particular period (prior to the deduction of the stockholder
servicing fees), in which case the excess will be accrued as a reduction to the estimated net asset value per share of each Class T share, which would result in the net asset value and distributions upon liquidation with respect to Class T shares
being lower than the net asset value and distributions upon liquidation with respect to Class A shares.” We respectfully request that you clear this comment.

4.
We note your disclosure on page 8 that, in the event of any voluntary or involuntary liquidation, dissolution or winding up, or any liquidating distribution of your assets, then such assets, or the proceeds therefrom,
will be distributed between the holders of Class A shares and Class T shares ratably in proportion to the respective NAV for each class until the NAV for each class has been paid. Please revise to clarify, if true, that NAV will be determined
as a whole for both Class A and Class T based on the aggregate assets and then any differences in NAV attributable to each class will be determined.

RESPONSE: In response to this comment, we have revised the disclosures on pages 7 and 150 of our prospectus to add the following
sentence: “We will calculate the net asset value per share as a whole for all Class A shares and Class T shares and then will determine any differences attributable to each class.” We respectfully request that you clear this comment.

 Distribution Declaration History, page 155

5.
We note your disclosure on page 156 that since your inception through June 30, 2015, the payment of distributions has been paid from offering proceeds. On page 8 of Supplement Number 3 in your post-effective
amendment filed on July 14, 2015, we further note you disclose that you paid 100% of distributions for the three months ended March 31, 2015 with cash flows provided by operations. Please reconcile these disclosures or advise.

 RESPONSE: In response to this comment, we note that on page 8 of Supplement Number 3 in our post-effective amendment
filed on July 14, 2015, the statement that 100% of distributions for

 September 24, 2015

 Page
 3

the three months ended March 31, 2015 were paid with cash flows from operations was followed by a paragraph that included the following statement: “From our inception through
March 31, 2015, the payment of distributions has been paid with a combination of offering proceeds and operating cash flows (which, for the three months ended March 31, 2015, were positively impacted by increases in amounts due to
affiliates and accounts payable and accrued liabilities).” For the three months ended March 31, 2015, we had cash on hand from operating cash flows that following the first quarter 2015, was used to pay amounts due to affiliates and
accounts payable. On an aggregate basis, and for the six months ended June 30, 2015, 100% of distributions were paid with offering proceeds. In light of the foregoing, we don’t believe that these disclosures are inconsistent. We
respectfully request that you clear this comment.

6.
Please revise your disclosure to show the relationship of the total distributions paid and earnings.

RESPONSE: In response to this comment, we have revised the distributions coverage table on page 156 of our prospectus to include a line
item for net loss and the first sentence of the paragraph immediately following the table to disclose the cumulative distributions and cumulative net loss. We respectfully request that you clear this comment.

Share Redemption Program, page 161

7.
We note your disclosure on page 164 that you received one request for the redemption of 1,750 shares which was fulfilled in July 2015. Please revise your disclosure to state the source of cash used to fund the
redemption request and the average price per share for the shares redeemed.

 RESPONSE: In response to this comment, we
have revised the disclosure on page 164 to include the information requested. We respectfully request that you clear this comment.

 The Company
acknowledges that:

•

should the SEC or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the SEC from taking any action with respect to the filing;

•

the action of the SEC or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in
the filing; and

•

the Company may not assert staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the SEC or any person under the federal securities laws of the United States.

 September 24, 2015

 Page
 4

 If you have any questions, or require additional information or documents, please contact the
undersigned (404.322.6627; mike.rafter@nelsonmullins.com) or Andrew Nielsen (404.322.6462; andrew.nielsen@nelsonmullins.com).

Very truly yours,

/s/ Michael K. Rafter

Michael K. Rafter

Mailstop 3233

September 3, 2015

Via E -mail
Paula Mathews
Executive Vice President and Secretary
Strategic Storage Trust II, Inc.
111 Corporate Drive, Suite 120
Ladera Ranch, CA  92694

Re: Strategic  Storage Trust II, Inc.
 Post -Effective Amendment to Form  S-11
Filed  August 27, 2015
 File No.  333-190983

Dear Ms. Mathews :

We have reviewed your  post-effective amendment  and have the following comments.  In
some of our comments, we may ask you to provide us with information so we may better
understand your disclosure.

Please respond to this letter by amending your registration statement  and providing the
requested information .  If you do not believe our comments apply to your facts and
circumstanc es or do not believe an amendment is appropriate, please tell us why in your
response.

After reviewing any amendment to your registration statement and the information you
provide in response to these  comments, we may have additional comments.

Q: Why are you offering two classes of your common stock, and what are the similarities and
differences between the classes?, page 7

1. Please revise to state how long a holder of a Class T share should  expect to pay the
stockholder servicing fee  and the aggregate  amount that a Class T holder should expect to
pay before reaching the 10% cap.

2. You state on page 7 that the stockholder servicing fee paid in respect of Class T shares
will be allocated to the Class T shares as a class expense, and these fees will impact  the
amount of distributions payable on all Class T shares, including those  purchased through
your distribution  reinvestment plan.  We further note that you will not pay stockholder
servicing fees with respect to shares sold pursuant to your distribution r einvestment plan.
Please revise to clarify how the stockholder servicing fee will impact the amount of

Paula Mathews
Strategic Storage Trust II, Inc.
September 3, 2015
Page 2

 distributions payable on the Class T shares purchased through the dividend reinvestment
plan or advise.

3. We note your disclosure on page 8 that, as a result of the allocation of the stockholder
servicing fee to the Class T shares, the Class T shares could have a lower net asset value
per share if distributions on the Class T shares are not adjusted to take account of such
fee.  We further note the pre ceding sentence that distributions on the Class T shares will
be lower than distributions on Class A shares because Class T shares are subject to the
on-going stockholder servicing fee.  Please revise to clarify or describe the circumstances
under which th e distributions on the Class T shares would not be adjusted to take account
of the stockholder servicing fee  or advise .  In addition, please tell us whether the
distribution amount on the Class T shares will increase once the 10% cap is reached.

4. We note  your disclosure on page 8 that, in the event of any voluntary or involuntary
liquidation, dissolution or winding up, or any liquidating distribution of your assets, then
such assets, or the proceeds therefrom, will be distributed between the holders of Cl ass A
shares and Class T shares ratably in proportion to the respective NAV for each class until
the NAV for each class has been paid.  Please revise to clarify, if true, that NAV will be
determined as a whole for both Class A and Class T based on the aggr egate assets and
then any differences in NAV attributable to each class will be determined.

Distribution Declaration History, page 155

5. We note your disclosure on page 156 that since your inception through June 30, 2015, the
payment of distributions has been paid from offering proceeds.  On page 8 of Supplement
Number 3 in your post -effective amendment filed on July 14, 2015, we further note you
disclose that you paid 100% of distributions for the three months ended March 31, 2015
with cash flows provided  by operations.  Please reconcile these disclosures or advise.

6. Please revise your disclosure to show the relationship of the total distributions paid and
earnings.

Share Redemption Program, page 161

7. We note your disclosure on page 164 that you receive d one request for the redemption of
1,750 shares which was fulfilled in July 2015.  Please revise your disclosure to state the
source of cash used to fund the redemption request and the average price per share for the
shares redeemed.

We urge all person s who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing includes the information the Securities Act of 193 3 and
all applicable Securities  Act rules require.   Since the company and its management are  in
possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.

Paula Mathews
Strategic Storage Trust II, Inc.
September 3, 2015
Page 3

Notwithstanding our comments, before we can declare the amended registration
statement effective, the com pany should provide us with a letter, acknowledging that:

 should the Commission or the staff, acting pursuant to delegated authority, declare the
filing effective, it does not foreclose the Commission from taking any action with respect
to the filing;

 the action of the Commission or the staff, acting pursuant to delegated authority, in
declaring the filing effective, does not relieve the company from its full responsibility for
the adequacy and accuracy of the disclosure in the filing; and

 the company may not assert staff comments and the declaration of effectiveness as a
defense in any proceeding initiated by the Commission or any person under the federal
securities laws of the United States.

Please contact  Coy Garrison, Staff Attorney , at (202 ) 551-3466, or me at  (202) 551 -3401
with any other questions.

Sincerely,

 /s/ Jennifer Gowetski

Jennifer Gowetski
Special Counsel
Office of Real Estate and
Commodities

cc: Michael K. Rafter, Esq.
 Nelson Mullins Riley & Scarborough LLP

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CORRESP

 MONARCH PLAZA

 SUITE 1600

3414 PEACHTREE ROAD N.E.

 ATLANTA, GEORGIA 30326

PHONE: 404.577.6000

 FAX: 404.221.6501

WWW.BAKERDONELSON.COM

 MICHAEL K. RAFTER

DIRECT DIAL: 404.443.6702

DIRECT FAX: 404.238.9626

MRAFTER@BAKERDONELSON.COM

February 19, 2015

 VIA E-MAIL

Ms. Jennifer Gowetsky

 United States Securities and
Exchange Commission

 Division of Corporate Finance

Washington, D.C. 20549

Re:
Strategic Storage Trust II, Inc. (the “Company”)

 Post-Effective Amendment No. 3
to Registration Statement on Form S-11

 Filed February 6, 2015

Your File No.: 333-190983

 Dear
Ms. Gowetsky:

 On behalf of our client, Strategic Storage Trust II, Inc. (the “Company”), we are submitting this letter
regarding the Company’s Post-Effective Amendment No. 3 to the Registration Statement on Form S-11 filed on February 6, 2015. This letter includes our responses to the comments received from you via telephone call on February 17,
2015, with Kara Davis of our firm. We have reproduced your comments and included our responses below each comment.

 1. Disclose in a
tabular format the Company’s distribution coverage, which includes total distributions, amounts used for the distribution reinvestment plan and amounts from offering proceeds and/or other financing sources. Also include a brief statement that
since all distributions are currently funded through offering proceeds, that it is dilutive to the Company’s stockholders. In addition, update the risk factor regarding distributions to state how much of the Company’s distributions have
come from offering proceeds.

 Response: In response to this comment, the Company agrees to include in its next supplement, filed
pursuant to Rule 424(b)(3) of the Securities Exchange Act of 1934, a table that discloses the Company’s distribution coverage in the manner you requested, a statement regarding how the use of offering proceeds to fund distributions affects
stockholders and an update to the risk factor regarding distributions to state how much of the Company’s distributions were funded with offering proceeds. We respectfully request that you clear this comment.

2. Sponsor & Affiliate Compensation—Disclose in tabular format the fees paid by the Company to its sponsor and its affiliates,
including offering fees, acquisition fees and management fees, fees incurred but not yet paid and whether the sponsor has paid any of the fees.

Response: Please note that the Company had disclosed in footnote 3 to its unaudited financial statements for the nine months ended
September 30, 2014, in tabular format, the fees and

 Ms. Jennifer Gowetsky

February 19, 2015

  Page
 2
 of 2

expenses incurred by the Company relating to the sponsor and its affiliates. However, In response to this comment, the Company agrees to include in its next supplement, filed pursuant to Rule
424(b)(3) of the Securities Exchange Act of 1934, a table that discloses the fees and expenses incurred by the Company relating to the sponsor and its affiliates, including offering fees, acquisition fees, and management fees, showing the fees paid
and payable to the sponsor and its affiliates. We respectfully request that you clear this comment.

 3. Redemption History – A
statement regarding redemption history should be included in each supplement that states either that no stockholders are currently eligible to redeem pursuant to the share redemption program or if there haven’t been any redemption requests or
if there have been requests, how many requests and whether the stockholders have been redeemed.

 Response: In response to this
comment, the Company agrees to include in its next supplement, filed pursuant to Rule 424(b)(3) of the Securities Exchange Act of 1934, a statement indicating that no redemptions were eligible to be made or actually made to date. We respectfully
request that you clear this comment.

 Through confirmation of this letter, we respectfully request that the United States Securities and
Exchange Commission declare effective the Company’s Post-Effective Amendment No. 3 to Registration Statement on Form S-11, filed on February 6, 2015. Please contact me as provided above if you have any additional questions or
comments.

Very truly yours,

/s/ Michael K. Rafter

Michael K. Rafter

 BAKER, DONELSON, BEARMAN,

CALDWELL & BERKOWITZ, PC

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ACCELERATION REQUEST

 January 8, 2014

VIA EDGAR and FACSIMILE

 Securities and Exchange
Commission

 Division of Corporation Finance

 100 F Street,
N.E., Mail Stop 4561

 Washington, D.C. 20549

 Attention: Tom
Kluck, Branch Chief

Re:
Strategic Storage Trust II, Inc.

 Registration Statement on Form S-11, as amended

File No. 333-190983

 Ladies and Gentlemen:

In accordance with Rule 461 under the Securities Act of 1933, Strategic Storage Trust II, Inc. (the “Company”) hereby requests that
the Securities and Exchange Commission (the “Commission”) accelerate the effective date of the above-captioned Registration Statement in order that the Registration Statement shall become effective at 9:00 A.M. (EDT) on January 10, 2014 or
as soon thereafter as practicable.

 In connection with the acceleration request, the Company hereby acknowledges that:

•

should the Commission or the staff, acting pursuant to delegated authority, declare the Registration Statement effective, it does not foreclose the Commission from taking any action with respect to the Registration
Statement;

•

the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the Registration Statement effective, does not relieve the Company from its full responsibility for the adequacy and
accuracy of the disclosure in the Registration Statement; and

•

the Company may not assert this action as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

 Tom Kluck, Branch Chief

January 8, 2014

 Page 2

Please contact Howard S. Hirsch of Baker, Donelson, Bearman, Caldwell & Berkowitz, PC, counsel to the Company, at (404) 443-6703 with any
questions about this acceleration request. Please notify us when the delegated authority copy of the order of the Commission declaring the Registration Statement effective has been executed.

Very truly yours,

Strategic Storage Trust II, Inc.

By:

/s/ H. Michael Schwartz

 H. Michael Schwartz

 Chief Executive Officer
and President

 cc: Mr. Coy Garrison

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filename1.htm

CORRESP

MONARCH PLAZA
 SUITE 1600

3414 PEACHTREE ROAD N.E.

 ATLANTA, GEORGIA
30326

 PHONE: 404.577.6000

 FAX: 404.221.6501

WWW.BAKERDONELSON.COM

 HOWARD S. HIRSCH

DIRECT DIAL: 404.443.6703

DIRECT FAX: 404.238.9703

HHIRSCH@BAKERDONELSON.COM

December 11, 2013

 VIA EDGAR

Mr. Tom Kluck

 Legal Branch Chief

United States Securities and Exchange Commission

 Division of
Corporate Finance

 Washington, D.C. 20549

Re:

Strategic Storage Trust II, Inc. (the “Company”)

Amendment No. 1 to Registration Statement on Form S-11

Filed October 31, 2013

Your File No.: 333-190983

 Dear Mr. Kluck:

On behalf of our client, Strategic Storage Trust II, Inc. (the “Company”), we are submitting this letter regarding the
Company’s Amendment No. 1 to the Registration Statement on Form S-11 filed on October 31, 2013. This letter includes our response to the comment letter from the staff of the Commission’s Division of Corporation Finance (the
“Staff”) to Michael S. McClure of the Company dated November 22, 2013 (the “Comment Letter”). The page number listed in the comment heading below corresponds to the page number listed in the Comment Letter. We have
reproduced the Staff’s comment verbatim and included our response below. The Company has filed today its Pre-Effective Amendment No. 2 to the Registration Statement (“Amendment No. 2”) via EDGAR, which reflects the response
below.

 Management, page 61

 1. We note your
disclosure on page 65 that Mr. Perry, one of your “independent directors” is also an independent director of Strategic Storage Trust, Inc. We also note your risk factor disclosure concerning Mr. Perry’s affiliation on page
26. Please expand upon your disclosure to discuss in more detail the conflicts of interest that Mr. Perry faces in your Conflicts of Interests sections beginning on pages 11 and 84.

Response: In response to this comment, please see the attached pages detailing the Company’s revisions to its Prospectus Summary,
Risk Factors, and Conflicts of Interest sections. Please note that the page numbers listed in the attachment correspond to the page numbers of Pre-Effective Amendment No. 2. We respectfully request that you clear this comment.

 Mr. Tom Kluck

December 11, 2013

 Page 2 of 4

Very truly yours,

 /s/ Howard S. Hirsch

Howard S. Hirsch

BAKER, DONELSON, BEARMAN,

CALDWELL & BERKOWITZ, PC

cc:

Mr. Coy Garrison

Mr. Michael S. McClure

 Mr. Tom Kluck

December 11, 2013

 Page 3 of 4

 Prospectus Summary, page 11

Conflicts of Interest

 Our advisor will
experience conflicts of interest in connection with the management of our business affairs, including the following:

•

The management personnel of our advisor and its affiliates also make investment decisions for Strategic Storage Trust, Inc., which we anticipate will have a first right to purchase certain self storage properties,
Strategic Storage Opportunity Trust, Inc. and other programs sponsored by our sponsor and its affiliates, many of which also invest in self storage properties. Consequently, management personnel will need to determine which investment opportunities
to recommend to us or an affiliated program or joint venture and also determine how to allocate resources among us and the other affiliated programs;

•

Our advisor may receive higher fees by providing an investment opportunity to an entity other than us;

•

We may engage in transactions with other programs sponsored by affiliates of our advisor or sponsor which may entitle such affiliates to fees in connection with their services, as well as entitle our advisor and its
affiliates to fees on both sides of the transaction;

•

We may structure the terms of joint ventures between us and other programs sponsored by our advisor or our sponsor and their affiliates;

•

Our advisor and its affiliates, including our property manager, will have to allocate their time between us and other real estate programs and activities in which they are involved, including Strategic Storage Trust,
Inc. and Strategic Storage Opportunity Trust, Inc.;

•

Our advisor and its affiliates will receive substantial fees in connection with transactions involving the purchase, management and sale of our properties regardless of the quality of the property acquired or the
services provided to us;

•

Our advisor may receive substantial compensation in connection with a potential listing or other liquidity event; and

•

One of our independent directors also serves as an independent director on the board of directors of Strategic Storage Trust, Inc.

These conflicts of interest could result in decisions that are not in our best interests. See the “Conflicts of Interest” and the
“Risk Factors — Risks Related to Conflicts of Interest” sections of this prospectus for a detailed discussion of the various conflicts of interest relating to your investment, as well as the procedures that we have established to
mitigate a number of these potential conflicts.

 Risk Factors, page 25

Our officers and one two of our directors face conflicts of interest related to the positions they hold with
affiliated entities, which could hinder our ability to successfully implement our investment objectives and to generate returns to you.

Our executive officers and one of our directors are also officers of our advisor, our property manager, and other affiliated entities,
including Strategic Storage Trust, Inc. and Strategic Storage Opportunity Trust, Inc. In addition, one of our independent directors is also an independent director of Strategic Storage Trust, Inc. As a result, these individuals owe fiduciary
duties to these other entities and their owners, which fiduciary duties may conflict with the duties that they owe to our stockholders and us. Their loyalties to these other entities could result in actions or inactions that are detrimental to our
business, which could harm the implementation of our investment objectives. Conflicts with our business and interests are most likely to arise from involvement in activities related to (1) allocation of new investments and management time and
services between us and the other entities, (2) our purchase of properties from, or sale of properties to, affiliated entities, (3) the timing and terms of the investment in or sale of an asset, (4) development of our properties by
affiliates, (5) investments with affiliates of our advisor, (6) compensation to our advisor, and (7) our relationship with our dealer manager and property manager. If we do not successfully implement our investment objectives, we may
be unable to generate cash needed to make distributions to you and to maintain or increase the value of our assets.

 Mr. Tom Kluck

December 11, 2013

 Page 4 of 4

 Conflicts of Interest, page 83

CONFLICTS OF INTEREST

 We
are subject to various conflicts of interest arising out of our relationship with our advisor and its affiliates, including conflicts related to the arrangements pursuant to which our advisor and its affiliates will be compensated by us. The
agreements and compensation arrangements between us and our advisor and its affiliates were not determined by arm’s-length negotiations. See the “Management Compensation” section of this prospectus. Some of the conflicts of interest
in our transactions with our advisor and its affiliates, and the limitations on our advisor adopted to address these conflicts, are described below.

Our advisor and its affiliates will try to balance our interests with their duties to other programs sponsored by our advisor and its
affiliates. However, to the extent that our advisor or its affiliates take actions that are more favorable to other entities than to us, these actions could have a negative impact on our financial performance and, consequently, on distributions to
our stockholders and the value of our stock. In addition, our directors, officers and certain of our stockholders may engage for their own account in business activities of the types conducted or to be conducted by us and our subsidiaries. For a
description of some of the risks related to these conflicts of interest, see the section of this prospectus captioned “Risk Factors — Risks Related to Conflicts of Interest.”

Our independent directors have an obligation to serve on our behalf in all situations in which a conflict of interest may arise, and all of
our directors have a fiduciary obligation to act on behalf of our stockholders.

 Interests in Other Real Estate Programs and Other Concurrent Offerings

 Affiliates of our advisor have sponsored or are sponsoring numerous public and private real estate programs with similar investment
objectives to us, including Strategic Storage Trust, Inc. and Strategic Storage Opportunity Trust, Inc. In addition, these REITs employ our sponsor’s investment strategy, which primarily focuses on self storage facilities and related self
storage real estate investments, and have acquired or plan to acquire assets similar to ours. Strategic Storage Opportunity Trust, Inc. focuses on opportunistic self storage assets, as more fully described below. The common investment strategy used
by each REIT would permit them to purchase certain properties that may also be suitable for our portfolio.

 Strategic Storage Trust, Inc.
has closed its primary offering; however, it expects to continue selling shares of its common stock pursuant to its distribution reinvestment plan. Strategic Storage Trust, Inc. raised approximately $546 million of gross offering proceeds in its
initial and follow-on public offerings. As of September 30, 2013, Strategic Storage Trust, Inc. has invested in a portfolio consisting of a total of 113 self storage properties in 17 states and Canada and may invest in additional properties
which may be similar to properties in which we invest. We anticipate that Strategic Storage Trust, Inc. will have a first right to purchase certain self storage properties. In addition, we may enter into transactions with Strategic Storage Trust,
Inc., including, without limitation, an acquisition, disposition or joint venture between the entities. Mr. Schwartz, our Chairman of the Board of Directors, Chief Executive Officer and President also serves as the Chairman of the Board of
Directors, Chief Executive Officer and President of Strategic Storage Trust, Inc., and Mr. Perry, one of our independent directors also serves as an independent director of Strategic Storage Trust, Inc. Both Mr. Schwartz and Mr. Perry
may have conflicts of interest in these transactions.

November 22, 2013

Via Email
Michael S. McClure
Chief Financial Officer and Treasurer
Strategic Storage Trust II, Inc.
111 Corporate Drive, Suite 120
Ladera Ranch, CA  92694

Re: Strategic Storage Trust II, Inc.
Amendment No. 1 to Registration Statement on Form S-11
  Filed October 31, 2013
  File No. 333 -190983

Dear Mr. McClure :

We have reviewed your filing  and have the following comment .  Please respond to this
letter by amending your registration statement and providing the requested information .  If you
do not believe our 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 registration statement  and the information you
provide in response to this comment , we may have  additional comments.

Management, page 61

1. We note your disclosure on page 65 that Mr. Perry, one of your “independent
directors” is also an independent director of Strategic Storage Trust, Inc.  We also note
your risk factor disclosure concerning Mr. Perry’s affiliation on page 26.  Please expand
upon your disclosure to discuss in more detail the conflicts of interest tha t Mr. Perry faces
in your Conflicts of Interests sections beginning on pages 11 and 84.

We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing includes the information the Secu rities Act of 193 3 and
all applicable Securities  Act rules require.   Since the company and its management are in
possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have mad e.

Notwithstanding our comment , in the event you request acceleration of the effective date
of the pending regist ration statement please provide  a written statement from the company
acknowledging that:

Michael S. McClure
Strategic Storage Trust II, Inc.
November 22, 2013
Page 2

  should the Commission or the staff, acting pursua nt to delegated authority, declare the
filing effective, it does not foreclose the Commission from taking any action with respect
to the filing;

 the action of the Commission or the staff, acting pursuant to delegated authority, in
declaring the filing effective, does not relieve the company from its full responsibility for
the adequacy and accuracy of the disclosure in the filing; and

 the company  may not assert staff comments and the declaration of effectiveness as a
defense in any proceeding initiated by the Commission or any person under the federal
securities laws of the United States.

Please refer to Rules 460 and 461 regarding requests for  acceleration .  We will consider a
written request for acceleration of the effective date of the registration statement as confirmation
of the fact that those requesting acceleration are aware of their respective responsibilities under
the Securities Act of  1933 and the Securities Exchange Act of 1934 as they relate to the proposed
public offering of the securities specified in the above registration statement.  Please allow
adequate time  for us to review any amendment prior to the requested effective date o f the
registration statement.

You may contact  Isaac Esquivel, Staff Accountant, at (202) 551 -3395 or Daniel Gordon,
Accounting Branch Chief, at (202) 551 -3486 if you have questions regarding comments on the
financial statements and related matters.  Please contact  Coy Garrison, Staff Attorney, at (202)
551-3466 or me at (202) 551 -3233 with any other questions.

Sincerely,

 /s/ Tom Kluck

Tom Kluck
Legal Branch Chief

cc: Howard S. Hirsch, Esq.

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SEC Response Letter

 MONARCH PLAZA

SUITE 1600

 3414 PEACHTREE
ROAD N.E.

 ATLANTA, GEORGIA 30326

PHONE: 404.577.6000

 FAX:
404.221.6501

 WWW.BAKERDONELSON.COM

 HOWARD S. HIRSCH

DIRECT DIAL: 404.443.6703

DIRECT FAX: 404.238.9703

HHIRSCH@BAKERDONELSON.COM

October 31, 2013

 VIA EDGAR

Mr. Michael McTiernan

 Assistant Director

United States Securities and Exchange Commission

 Division of
Corporate Finance

 Washington, D.C. 20549

Re:
Strategic Storage Trust II, Inc. (the “Company”)

 Registration Statement on Form S-11

 Filed September 4, 2013

Your File No.: 333-190983

 Dear
Mr. McTiernan:

 On behalf of our client, Strategic Storage Trust II, Inc. (the “Company”), we are submitting this letter
regarding the Company’s Registration Statement on Form S-11 filed on September 4, 2013. This letter includes our response to the comment letter from the staff of the Commission’s Division of Corporation Finance (the “Staff”)
to Michael S. McClure of the Company dated September 30, 2013 (the “Comment Letter”). The headings and paragraph numbers below correspond to those of the Comment Letter. We have reproduced the Staff’s comments and included our
responses below each comment. The Company has filed today Pre-Effective Amendment No. 1 to the Registration Statement (“Amendment No. 1”) via EDGAR, which reflects the responses below. Please note that all page numbers provided
in the responses below correspond to the pages of Amendment No. 1.

 General

1.    We note your disclosure that you are an “emerging growth company,” as defined in the Jumpstart Our Business Startups Act,
please:

•

Describe how and when a company may lose emerging growth company status;

•

Briefly describe the various exemptions that are available to you, such as exemptions from Section 404(b) of the Sarbanes-Oxley Act of 2002 and Section 14A(a) and (b) of the Securities Exchange Act of
1934; and

•

State your election under Section 107(b) of the JOBS Act:

 Mr. Michael McTiernan

October 31, 2013

  Page
 2
 of 8

¡

If you have elected to opt out of the extended transition period for complying with new or revised accounting standards pursuant to Section 107(b), include a statement that the election is irrevocable; or

¡

If you have elected to use the extended transition period for complying with new or revised accounting standards under Section 102(b)(1), provide a risk factor explaining that this election allows you to delay the
adoption of new or revised accounting standards that have different effective dates for public and private companies. Please state in your risk factor that, as a result of this election, your financial statements may not be comparable to companies
that comply with public company effective dates. Include a similar statement in your critical accounting policy disclosures.

Response:    In response to this comment, please see the additional section titled, “What is the impact of
being an “emerging growth company”?” added to the Questions and Answers section of the prospectus on pages 5-6 of Amendment No. 1 as well as the risk factor added on page 24 of Amendment No. 1. We respectfully request that
you clear this comment.

 2.    Please supplementally provide us with copies of all written communications, as defined in Rule 405
under the Securities Act, that you or anyone authorized to do so on your behalf, present to potential investors in reliance on Section 5(d) of the Securities Act, whether or not they retain copies of the communications. Similarly, please
supplementally provide us with any research reports about you that are published or distributed in reliance upon Section 2(a)(3) of the Securities Act of 1933 added by Section 105(a) of the Jumpstart Our Business Startups Act by any broker
or dealer that is participating or will participate in your offering.

 Response:    In response to this
comment, we hereby confirm on behalf of the Company that, as of the date of this letter, no written communications have been presented to potential investors in reliance on Section 5(d) of the Securities Act, and there have been no research
reports about the Company that have been published or distributed in reliance upon Section 2(a)(3) of the Securities Act. On behalf of the Company, we hereby undertake to provide you with copies of such written communications or research
reports to the extent they are generated and used in connection with this offering. We respectfully request that you clear this comment.

3.    Please note that any sales literature that is to be used in connection with this offering must be submitted to us prior to use,
including sales literature intended for broker-dealer use only. Please submit all written sales materials proposed to be transmitted to prospective investors, orally or in writing. Please be aware that we will need time to review these materials. In
addition, note that sales materials must set forth a balanced presentation of the risks and rewards to investors and should not contain any information or disclosure that is inconsistent with or not also provided in the prospectus. For guidance,
refer to Item 19.D of Industry Guide 5.

 Response:    In response to this comment, we hereby confirm on
behalf of the Company that we will provide you with all sales literature that is to be used in connection with this offering, including material that will be used only by broker-dealers, prior to the use of such sales literature. Additionally, all
such material and sales literature will set forth a balanced presentation of the risks and rewards to investors and will not contain any information or disclosure that is inconsistent with or not also provided in the prospectus, consistent with
Item 19.D of Industry Guide 5. We respectfully request that you clear this comment.

 Mr. Michael McTiernan

October 31, 2013

  Page
 3
 of 8

4.    Please provide us with copies of any graphics, maps, photographs, and related captions or other artwork including logos that you intend to use in the prospectus. Such
graphics and pictorial representations should not be included in any preliminary prospectus distributed to prospective investors prior to our review.

Response:    In response to this comment, we direct you to the graphs on pages 59 and 60 of Amendment No. 1.
In addition, the Company anticipates it will have a logo and we will forward you a copy of such logo once created. We do not intend to provide preliminary prospectuses to prospective investors prior to the effective date of the offering.

5.    Please be advised that you are responsible for analyzing the applicability of the tender offer rules, including Rule 13e-4 and
Regulation 14E, to your share repurchase program. We urge you to consider all the elements of your share repurchase program in determining whether the program is consistent with relief granted by the Division of Corporation Finance in prior no
action letters. See, for example, T REIT Inc. (Letter dated June 4, 2001) and Wells Real Estate Investment Trust II, Inc. (Letter dated December 3, 2003). To the extent you have questions as to whether the program is entirely consistent
with the relief previously granted by the Division of Corporation Finance, you may contact the Division’s Office of Mergers and Acquisitions.

Response:    In response to this comment, the Company acknowledges that it is responsible for analyzing the
applicability of the tender offer rules, including Rule 13e-4 and Regulation 14E, to the Company’s share redemption program. We will contact the Division’s Office of Mergers and Acquisitions on behalf of the Company if we have any
questions regarding whether the Company’s share redemption program is consistent with relief previously granted by the Division of Corporation Finance. We respectfully request that you clear this comment.

6.    We note that you may conduct the share repurchase program during the offering period of the shares being registered under this
registration statement. Please be advised that you are responsible for analyzing the applicability of Regulation M to your share repurchase program. We urge you to consider all the elements of your share repurchase program in determining whether the
program is consistent with the class relief granted by the Division of Market Regulation in the class exemptive letter granted Alston & Bird LLC dated October 22, 2007. To the extent you have questions as to whether the program is
entirely consistent with that class exemption you may contact the Division of Trading and Markets.

Response:    In response to this comment, the Company acknowledges that it is responsible for analyzing the
applicability of Regulation M to the Company’s share redemption program. We will contact the Division’s Office of Market Regulation on behalf of the Company if we have any questions regarding whether the Company’s share redemption
program is consistent with relief previously granted by the Division of Market Regulation. We respectfully request that you clear this comment.

Prospectus Cover Page

 7.    In the
first bullet point summary risk factor, please clarify that you are not required to ever provide a liquidity event. Additionally, please revise your disclosure on pages 17, 19 and elsewhere as appropriate.

Response:    In response to this comment, we have revised the first bullet point summary risk factor on the cover
page and the disclosures on pages 10, 15, 19 and 50 in Amendment No. 1 to clarify that the Company is not required to ever provide a liquidity event.

 Mr. Michael McTiernan

October 31, 2013

  Page
 4
 of 8

 Questions and Answers About This Offering, page 1

8.    We note that certain disclosures in this section are repeated in the Prospectus Summary. For example, the same risk factors are
disclosed on pages 5-7 and pages 17-18. Please revise to limit the use of repetition where possible.

Response:    In response to this comment, we have deleted the “What are some of the more significant risks
involved in an investment in your shares?” section in the Questions and Answers portion of the prospectus in Amendment No. 1 as it is repetitive to the “Summary Risk Factors” section on pages 10-11 of Amendment No. 1. We
have also deleted the “What will you do with the money raised in this offering?” section in the Questions and Answers portion of the prospectus as it is repetitive to the “Estimated Use of Proceeds” section on page 14 of
Amendment No. 1.

 How long will this offering last?; page 3

9.    We note your disclosure that the length of the primary offering may be extended. If the primary offering may extend over subsequent
registration statements, please revise to clarify.

 Response:    In response to this comment, please see our
change to “How long will this offering last?” on pages 3-4 of Amendment No. 1.

 Conflicts of Interest, page 11

10.    We note that your advisor will face conflicts of interest in allocating investment opportunities among affiliated entities. Please
supplement your first bullet point to identify the existing conflict with Strategic Storage Trust, Inc., to disclose Strategic Storage Trust, Inc.’s offering size, and to state that you anticipate it to have the first right to purchase certain
self-storage properties, per your disclosure on page 25. Additionally, please provide a more detailed description of Strategic Storage Opportunity Trust, Inc., including its offering size, its current stage of the REIT business cycle, and its
competing activities, if any.

 Response:    In response to this comment, please see the changes on pages 10, 84
and 85 of Amendment No. 1.

 Summary Risk Factors, page 17

11.    Please include a summary risk factor related to the arbitrary nature of the offer price. We note your risk factor on page 20.

Response:    In response to this comment, we have added the risk factor to the summary risk factors on page 10 of
Amendment No. 1.

 12.    Please include a summary risk factor related to your lack of ownership of the intellectual property
rights to the “SmartStop® Self Storage” brand. We note your risk factor on page 23.

Response:    In response to this comment, we have added the risk factor to the summary risk factors on page 10 of
Amendment No. 1.

 Mr. Michael McTiernan

October 31, 2013

  Page
 5
 of 8

 You may be unable to sell your shares…, page 20

13.    It appears that even with the discounts applied to the redemption price, redeeming investors will still receive more than the
proceeds received by the company as a result of the investment. If accurate, please include a risk factor regarding the likelihood that redemptions will dilute remaining shareholders.

Response:    It is not possible for the Company to determine whether redemptions will dilute remaining
stockholders. Whether or not redemptions will result in a dilution of remaining stockholders is dependent upon the net asset value of the Company’s common stock at the time of redemption. Pursuant to the Company’s share redemption program,
the Company will not redeem any shares that have not been held for at least a year; therefore, no redemptions will be made during the Company’s first year. After that time, if at any point the Company determines that the net asset value of its
common stock is less than the amount shares may be redeemed pursuant to its share redemption program, the Company will include a risk factor in its prospectus at that time.

Investors who invest in us at the beginning of our offering…, page 22

14.    We note your disclosure that until you can generate sufficient cash flow from operations, “distributions, if any will be paid
from other sources, such as from the proceeds of this or other offerings.” We also note your disclosures that you “may” use offering proceeds to fund distributions on pages 3, 15 and 21. If you intend to pay distributions in excess of
cash flow from operations, please revise your disclosures to include an affirmative statement to that effect and revise the disclosures on pages 3, 15, 21, and elsewhere, to be consistent with your affirmative statement on page 22 that until you can
generate sufficient cash flow from operations, distributions will be paid from offering proceeds.

Response:    In response to this comment, we have revised our disclosures to include an affirmative statement to
the effect that we will likely pay, initially, distributions in excess of cash flow from operations. Please see the changes on the cover page and pages 3, 16 and 21 of Amendment No. 1.

The Self Storage Industry, page 57

15.    Please provide us with support for the quantitative and qualitative business and industry data used here and elsewhere in the
registration statement. Please note that the requested information should be filed as EDGAR correspondence or, alternatively, should be sent in paper form accompanied by a cover letter indicating that the material is being provided pursuant to
Securities Act Rule 418 and that such material should be returned to the registrant upon completion of the staff review process. Please also highlight the specific portions that you are relying upon so that we can reference them easily. In addition,
please confirm to us that any third party data included in the registration statement was not prepared for or commissioned by the registrant or its affiliates.

Response:    In response to this comment, we are sending you, in paper form, the materials you have requested. Such
materials are being provided pursuant to Securities Act Rule 418.

 Management, page 60

16.    We note your disclosure that your charter was reviewed by a majority of the board of directors, including a majority of independent
directors. We also note that you currently have no independent directors. Please advise.

 Mr. Michael McTiernan

October 31, 2013

  Page
 6
 of 8

 Response:    In response to this comment, we acknowledge that the
Company had not yet selected its full board of directors as of the

September 30, 2013

Via Email
Michael S. McClure
Chief Financial Officer and Treasurer
Strategic Storage Trust II, Inc.
111 Corporate Drive, Suite 120
Ladera Ranch, CA  92694

Re: Strategic Storage Trust II, Inc.
Registration Statement on Form S-11
Filed September 4, 2013
  File No. 333 -190983

Dear Mr. McClure :

We have reviewed your registration statement  and have the following comments.  In
some of our comments, we may ask you  to provide us with information so we may better
understand your disclosure.

Please respond to this letter by amending your registration statement and providing the
requested information .  If you do not believe our comments apply to your facts and
circums tances or do not believe an amendment is appropriate, please tell us why in your
response.

After reviewing any amendment to your registration statement and the information you
provide in response to these  comments, we may have  additional comments.

General

1. We note your disclosure that you are an “emerging growth company,” as defined in the
Jumpstart Our Business Startups Act, please:

 Describe how and when a company may lose emerging growth company status;
 Briefly describe the various exemptions that  are available to you, such as
exemptions from Section 404(b) of the Sarbanes -Oxley Act of 2002 and Section
14A(a) and (b) of the Securities Exchange Act of 1934; and
 State your election under Section 107(b) of the JOBS Act:
o If you have elected to opt out of the extended transition period for complying
with new or revised accounting standards pursuant to Section 107(b), include
a statement that the election is irrevocable; or

Michael S. McClure
Strategic Storage Trust II, Inc.
September 30, 2013
Page 2

 o If you have elected to use the extended transition period for complying with
new or revised accounting standards under Section 102(b)(1), provide a risk
factor explaining that this election allows you to delay the adoption of new or
revised accounting standards that have different effective dates for public and
private companies until those standards apply to private companies.  Please
state in your risk factor that, as a result of this election, your financial
statements may not be comparable to companies that comply with public
company effective dates.  Include a similar statement in your critical
accounting policy disclosures.
2. Please supplementally provide us with copies of all written communications, as defined
in Rule 405 under the Securities Act, that you or anyone authorized to do so on your
behalf, present to potential investors in reliance on Section 5(d) of the Securities Act,
whether or not they retain copies of the communications.  Similarly, please
supplementally provide us with any research reports about you that are published or
distributed in reliance upon Section 2(a)(3) of the Securities Act of 1933 added by
Section 105(a) of the Jumpstart Our Business Startups Act by any broker or dealer that is
participating or will participate in your offering.
3. Please note that any sales literature that is to be used in connection with  this offering
must be submitted to us prior to use, including sales literature intended for broker -dealer
use only.  Please submit all written sales materials proposed to be transmitted to
prospective investors, orally or in writing.  Please be aware that  we will need time to
review these materials.  In addition, note that sales materials must set forth a balanced
presentation of the risks and rewards to investors and should not contain any information
or disclosure that is inconsistent with or not also pr ovided in the prospectus.  For
guidance, refer to Item 19.D of Industry Guide 5.
4. Please provide us with copies of any graphics, maps, photographs, and related captions or
other artwork including logos that you intend to use in the prospectus.  Such grap hics and
pictorial representations should not be included in any  preliminary prospectus distributed
to prospective investors prior to our review .

5. Please be advised that you are responsible for analyzing the applicability of the tender
offer rules, incl uding Rule 13e -4 and Regulation 14E, to your share repurchase
program.   We urge you to consider all the elements of your share repurchase program in
determining whether the program is consistent with relief granted by the Division of
Corporation Finance in  prior no action letters.  See, for example, T REIT Inc. (Letter
dated June  4, 2001) and Wells Real Estate Investment Trust II, Inc. (Letter dated
December  3, 2003).   To the extent you have questions as to whether the program is
entirely consistent with th e relief previously granted by the Division of Corporation
Finance, you may contact the Division’s Office of Mergers and Acquisitions.

Michael S. McClure
Strategic Storage Trust II, Inc.
September 30, 2013
Page 3

 6. We note that you may conduct the share repurchase program during the offering period of
the shares being registered under this registration statement.   Please be advised that you
are responsible for analyzing the applicability of Regulation M to your share repurchase
program.   We urge you to consider all the elements of your share repurchase program in
determining wheth er the program is consistent with the class relief granted by the
Division of Market Regulation in the class exemptive letter granted Alston & Bird LLP
dated October 22, 2007.   To the extent you have questions as to whether the program is
entirely consiste nt with that class exemption you may contact the Division of Trading and
Markets.

Prospectus Cover Page

7. In the first bullet point summary risk factor, please clarify that you are not required to
ever provide a liquidity event.  Additionally, please revise your disclosure on pages 17,
19, and elsewhere as appropriate.

Questions and Answers About This Offering, page 1

8. We note that certain disclosures in this section are repeated in the Prospectus Summary.
For example, the same risk factors are disclosed on pages 5 -7 and pages 17 -18.  Please
revise to limit the use of repetition where possible.

How long will this o ffering last?, page 3

9. We note your disclosure that the length of the primary offering may be extended.  If the
primary offering may extend over subsequent registration statements, please revise to
clarify.

Conflicts of Interest, page 11

10. We not e that your advisor will face conflicts of interest in allocating investment
opportunities among affiliated entities.  Please supplement your first bullet point to
identify the existing conflict with Strategic Storage Trust, Inc., to disclose Strategic
Storage Trust, Inc.’s offering size, and to state that you anticipate it to have the first right
to purchase certain self -storage properties, per your disclosure on page 25.  Additionally,
please provide a more detailed description of Strategic Storage Opport unity Trust, Inc.,
including its offering size, its current stage of the REIT business cycle, and its competing
activities, if any.

Summary Risk Factors, page 17

11. Please include a summary risk factor related to the arbitrary nature of the offer pric e.  We
note your risk factor on page 20.

Michael S. McClure
Strategic Storage Trust II, Inc.
September 30, 2013
Page 4

 12. Please include a summary risk factor related to your lack of ownership of the intellectual
property rights to the “SmartStop® Self Storage” brand.  We note your risk factor on
page 23.

You may be unable to sell your shares . . ., page 20

13. It appears that even with the discounts applied to the redemption price, redeeming
investors will still receive more than the proceeds received by the company as a result of
the investment.  If accurate, please include a risk factor regarding the likelihood that
redemptions will dilute remaining shareholders.

Investors who invest in us at the beginning of our offering . . . , page 22

14. We note your disclosure that until you can generate sufficient cash flow from operations,
“distributions, if any, will be paid from other sources, such as from the proceeds of this or
other offerings.”  We also note your disclosures that you “may” use offe ring proceeds to
fund distributions on pages 3, 15, and 21.  If you intend to pay distributions in excess of
cash flow from operations, please revise your disclosures to include an affirmative
statement to that effect and revise the disclosures on pages 3,  15, 21, and elsewhere, to be
consistent with your affirmative statement on page 22 that until you can generate
sufficient cash flow from operations, distributions will be paid from offering proceeds.

The Self Storage Industry, page 57

15. Please provid e us with support for the quantitative and qualitative business and industry
data used here and elsewhere in the registration statement.  Please note that the requested
information should be filed as EDGAR correspondence or, alternatively, should be sent
in paper form accompanied by a cover letter indicating that the material is being provided
pursuant to Securities Act Rule 418 and that such material should be returned to the
registrant upon completion of the staff review process.  Please also highlight th e specific
portions that you are relying upon so that we can reference them easily.  In addition,
please confirm to us that any third party data included in the registration statement was
not prepared for or commissioned by the registrant or its affiliates .

Management, page 60

16. We note your disclosure that your charter was reviewed by a majority of the board of
directors, including a majority of independent directors.  We also note that you currently
have no independent directors.  Please advise.

Executive Officers and Directors, page 62

17. Please revise to include Mr. Schwartz’s involvement with U.S. Advisor, LLC, from 2004
through 2007.  We note your disclosure on page 95.

Michael S. McClure
Strategic Storage Trust II, Inc.
September 30, 2013
Page 5

 The Advisory Agreement, page 72

18. Please revise your disclosure that  your operating partnership “may” be required to make
distributions to your advisor upon the termination of the advisory agreement for any
reason other than a material breach by your advisor, to be consistent with your
affirmative statement on page 78 that  you will have to pay your advisor distributions
under these circumstances.

Management Compensation, page 79

19. In future filings that require Item 402 or Item 404 of Regulation S -K disclosure, please
disclose the amount of fees paid to the advisor, b reak out the amounts paid pursuant to
the reimbursement provision, and, within reimbursements, specify any amounts
reimbursed for salaries or benefits of a named executive officer and, as applicable, other
key personnel.

Prior Performance Summary, page 95

20. Please revise to disclose the number of properties sold during the course of the prior
public and private programs.  Refer to Item 8.A.1.h of Industry Guide 5.

21. Please revise your narrative of the six private programs that are most similar to your
offering to disclose which programs have completed operations and to provide
information relating to the sale of properties by these programs.

Subscription Procedur es, page 153

22. Please revise your disclosure to clarify whether purchases of your shares by your
affiliates will count toward the minimum offering amount.

Appendix C, Prior Performance Tables, page C -1

23. Please cross -reference the narrative summary  of these prior programs in the registration
statement, as appropriate.  Refer to Instructions to Appendix II - Prior Performance Tables
to Industry Guide 5.

Table V, C -12

24. Please provide footnote disclosure explaining the cash distributions character ized as
“other.”  In addition, please provide us support for the distribution data provided for Self
Storage REIT, Inc. and Madison County Self Storage, DST.

Michael S. McClure
Strategic Storage Trust II, Inc.
September 30, 2013
Page 6

 Table VI, C -15

25. Please move Table VI to Part II of the registration statement.  Refer to Item 8.B of
Industry Guide 5.

Exhibit Index

26. We note that the exhibit list includes “form of” agreements.  Please advise us if you do
not intend on filing final, executed agreements prior to effectiveness of the registration
statement.  Please be advised that to the extent you are unable to file fina l and executed
forms as exhibits, they may not be subsequently incorporated by reference.

Exhibit 5.1, Form of Opinion as to Legality of Securities

27. We note your fourth assumption on page two of the letter.  Please revise to specifically
identify the  restrictions or limitations in the Charter that you are referring to.

We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing includes the information the Securities Act of 19 33 and
all applicable Securities  Act rules require.   Since the company and its management are in
possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.

Notwithsta nding our comments, in the event you request acceleration of the effective date
of the pending regist ration statement please provide  a written statement from the company
acknowledging that:

 should the Commission or the staff, acting pursuant to delegated authority, declare the
filing effective, it does not foreclose the Commission from taking any action with respect
to the filing;

 the action of the Commission or the staff, acting pursuant to delegated authority, in
declaring the filing effective, does no t relieve the company from its full responsibility for
the adequacy and accuracy of the disclosure in the filing; and

 the company may not assert staff comments and the declaration of effectiveness as a
defense in any proceeding initiated by the Commissio n or any person under the federal
securities laws of the United States.

Please refer to Rules 460 and 461 regarding requests for  acceleration .  We will consider a
written request for acceleration of the effective date of the registration statement as con firmation
of the fact that those requesting acceleration are aware of their respective responsibilities under
the Securities Act of 1933 and the Securities Exchange Act of 1934 as they relate to the proposed
public offering of the securities specified in t he above registration statement.  Please allow

Michael S. McClure
Strategic Storage Trust II, Inc.
September 30, 2013
Page 7

 adequate time  for us to review any amendment prior to the requested effective date of the
registration statement.

You may contact  Isaac Esquivel, Staff Accountant, at (202) 551 -3395 or Daniel Gordon,
Accounting Branch Chief, at (202) 551 -3486 if you have questions regarding comments on the
financial statements and related matters.  Please contact  Coy Garrison, Staff Attorney, at (20 2)
551-3466 or me at (202) 551 -3852 with any other questions.

Sincerely,

 /s/ Michael McTiernan

Michael McTiernan
Assistant Director

cc: Howard Hirsch, Esq.