UNITED STATES
                                 SECURITIES AND EXCHANGE COMMISSION
                                              WASHINGTON, D.C. 20549


    DIVISION OF
CORPORATION FINANCE


                                                                      March 4,
2020


 Ziv Sapir
 Comrit Investments 1, LP
 9 Ahad Ha'am Street
 Tel Aviv, Israel 6129101

         Re:     Healthcare Trust, Inc.
                 Schedule TO-T
                 Filed February 26, 2020 by Comrit Investments 1, Limited
Partnership
                 File No. 005-89596

 Dear Mr. Sapir:

         We have reviewed the above-captioned filing, and have the following
comments. Please
 respond by replying in writing to this letter and providing us with any
requested additional
 information and/or amending the filing. If you do not believe a comment
applies to your facts
 and circumstances and/or do not believe an amendment is appropriate, please
advise us why.

        After reviewing any amendment to the filing and any information
provided in response to
 these comments, we may have additional comments.

 Schedule TO-T

 Item 10. Financial Statements

 1. Given that the tender offer seeks to buy less than all of the outstanding
class of securities, and
    the named bidder is not subject to the periodic reporting requirements
under the Securities
    Exchange Act of 1934 and rules thereunder, the safe harbor codified at
Instruction 2 to Item
    10 of Schedule TO is unavailable. Please provide us with a brief legal
analysis that explains
    the basis for the position that the financial condition of the bidder is
immaterial to a
    shareholder's decision whether or not to participate in the tender offer.
Alternatively, please
    revise to disclose the information required by Item 10 of Schedule TO.

 Exhibit 95(a)(1)   Offer to Purchase

 2. Disclosure on the first page indicates that notice of any such extension,
termination, or
    amendment will promptly be disseminated in compliance with Rule 14d-4(c).
The provision
    that regulates dissemination of such notices, however, has been codified at
Rule 14d-4(d)(1).
    Please revise.
 Ziv Sapir
Comrit Investments 1, LP
March 4, 2020
Page 2

Is the financial conditions of the bidders relevant to my decision to tender in
the offer?, p. 4

3. In the context of addressing the sources of funds available to consummate
the tender offer,
   the representation has been made that "the Purchaser has more than adequate
resources." For
   example, in response to a question posed on page 4 directly preceding the
one captioned
   above, the disclosure indicates "the Purchaser currently has sufficient
funded capital to fund
   all of its commitments under this Offer." Please provide us with the factual
foundation for
   these assertions, and advise us whether or not the cash needed to purchase
the securities is
   already available or if the availability of the financial resources is
subject to any
   contingencies. Refer to Item 11 of Schedule TO and corresponding Item
1011(c) of
   Regulation M-A as well as Section 14(e) of the Securities Exchange Act of
1934.

Section 5. Extension of Tender Period; Termination; Amendment, page 11

4. The disclosure indicates that if the Purchaser makes a material change in
the terms of the
   Offer or the information concerning the Offer or waives a material condition
of the Offer, the
   Purchaser will extend the Offer to the extent required by Rules 14d-4(c) and
14d-6(d). Both
   of those rule provisions, however, seem inapplicable in the context of a
material change.
   Please revise to cite exclusively to Rule 14d-4(d)(1) and Rule 14e-1, or
advise.

Exhibit 99.(a)(4) | Notice of Offer to Purchase for Cash

5. To the extent that the bidder relied upon "Summary publication" as described
in Rule 14d-
   4(a)(2) to disseminate the tender offer to security holders, please advise
us of the medium
   through which the notice was distributed. Alternatively, please advise us
how the bidder
   otherwise complied with Rule 14d-4(a).

                                          *       *        *

       We remind you that the Purchaser is responsible for the accuracy and
adequacy of its
disclosures, notwithstanding any review, comments, action or absence of action
by the staff.

        You may contact me at (202) 551-3266 with any questions.


                                                               Sincerely,

                                                               /s/ Nicholas P.
Panos

                                                               Nicholas P.
Panos
                                                               Senior Special
Counsel
                                                               Office of
Mergers & Acquisitions

cc:    Amos W. Barclay, Esq.