December 10, 2024

Robert Dixon
Chief Executive Officer
MacKenzie Realty Capital, Inc.
89 Davis Road
Suite 100
Orinda, CA 94563

       Re: MacKenzie Realty Capital, Inc.
           Registration Statement on Form S-3
           Filed November 26, 2024
           File No. 333-283478
Dear Robert Dixon:

       We have conducted a limited review of your registration statement and
have the
following comments.

        Please respond to this letter by amending your registration 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 registration statement and the
information
you provide in response to this letter, we may have additional comments.

Registration Statement on Form S-3
Description of Securities We May Offer, page 9

1.     We note that you are registering rights. Please revise to provide a
description of the
       rights that you may offer. Refer to Item 202 of Regulation S-K.
General

2.     We note your disclosure that Maxim Group will sell up to $15,000,000
pursuant to an
       equity distribution agreement. However, we also note your disclosure
that under this
       agreement, you may sell up to $20,000,000, which is also the amount
provided by the
       agreement filed as Exhibit 1.2. Please revise your disclosure to address
this
       discrepancy or otherwise clarify that you are registering a different
amount.
       Additionally, please file the executed agreement.
 December 10, 2024
Page 2

        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.

       Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate
time for us to review any amendment prior to the requested effective date of
the registration
statement.

       Please contact Stacie Gorman at 202-551-3585 or Dorrie Yale at
202-551-8776 with
any questions.



                                                           Sincerely,

                                                           Division of
Corporation Finance
                                                           Office of Real
Estate & Construction
cc:   Steve Barrett, Esq.