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


    DIVISION OF
 CORPORATION FINANCE


                                                       May 3, 2019



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

RE:    New York City REIT Incorporated
       Schedule TO-T filed April 30, 2019
       Filed by Comrit Investments I, Limited Partnership
       File No. 005-90261

Dear Mr. Sapir:

        We have reviewed the above-captioned filing and have the following
comments. Some
of our comments may ask for information so we may better understand your
disclosure. If you
do not believe our comments apply to your facts and circumstances, and/or do
not believe an
amendment is appropriate, please tell us why in a written response.

       Please respond to this letter by amending the filing and/or by providing
the requested
information. After reviewing this information and/or amendment to this filing,
we may raise
additional comments.

Schedule TO-T

Cover Page | General

1. While we recognize you have executed the Schedule TO as an authorized
representative of
   Comrit Investments Ltd., the General Partner of the named bidder, neither
you nor Comrit
   Investments Ltd. have been identified as co-bidders in the Offer to
Purchase. General
   Instruction K.(1) of Schedule TO, codified at Rule 14d-100, defines the term
offeror
   consistent with the term "bidder" as defined in Rule 14d-1(g)(2) to include
persons on whose
   behalf the offer is being made. Please advise us, with a view toward revised
disclosure,
   whether or not you and the General Partner should be identified as
co-Offerors. To the
   extent a conclusion is reached that the tender offer is not being conducted
on your collective
   behalf, please advise us what steps have been taken to provide disclosure
pursuant to General
   Instruction C to Schedule TO with respect to both you and the General
Partner.
 Ziv Sapir
Comrit Investments 1, LP
May 3, 2019
Page 2

What is the Market Value of my Shares?, page 5

2. Please advise us why the Offer to Purchase does not reference publicly
available secondary
   market trading prices. We noticed, for example, that the entity engaged to
facilitate
   settlement and payment in your offer, Central Trade and Transfer, LLC, also
operates a
   website, CTTAuctions.com, that may include pricing information. In order to
assure
   compliance with Section 14(e), the "bidder should disclose the prices at
which recent sales
   have been made, to the extent known or reasonably available, even when there
is no
   established market." See SEC Interpretation: Commission Guidance on
Mini-Tender Offers
   and Limited Partnership Tender Offers, Exchange Act Release No. 43069 (July
24, 2000).

Section 10. Certain Information Concerning the Purchaser.

3. Because the tender offer is for less than all of New York REIT's outstanding
common stock, the
   "safe harbor" memorialized in Instruction 2 to Item 10 of Schedule TO is
unavailable for
   purposes of justifying the omission of audited and unaudited financial
statements. Please advise
   us whether or not the bidder(s) believe(s) that the financial information
specified in Item 10 is
   immaterial in the context of this offer, and if so, the basis for such
belief.

Section 15. Miscellaneous, page 11

4. Given the disclosure regarding the possibility that a court may revoke or
choose not to
   enforce an arbitration agreement, please revise to qualify the assertion
that "the arbitrator's
   decision will be final and binding on all parties."

5. Please revise the existing disclosure regarding fee recovery to describe:
any minimum level
   required by the plaintiff to avoid payment; who exactly is eligible to
recover (e.g., bidder, its
   affiliates, tendering holders, tendering holders whose shares are purchased
in the offer); and any
   fees that may not be recovered such as unreasonable attorney's fees and
costs, or advise.

   Closing Comments

       If the information you provide in response to our comments materially
changes the
information already provided to shareholders, disseminate the revised materials
in a manner
reasonably calculated to inform them of the new information.

         We urge all persons who are responsible for the accuracy and adequacy
of the disclosure
in the filings reviewed by the staff to be certain that they have provided all
information investors
require for an informed decision. Since the offeror is in possession of all
facts relating to its
disclosure, it is responsible for the accuracy and adequacy of the disclosures
it has made.
 Ziv Sapir
Comrit Investments 1, LP
May 3, 2019
Page 3

       Please direct any questions to me at (202) 551-3266.


                                                   Sincerely,

                                                   /s/ Nicholas P. Panos

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

cc: Amos W. Barclay, Esq.