March 17, 2025

Alfred Lee Finley
Director
Medalist Diversified REIT, Inc.
850 Industrial Avenue
Saginaw, Texas 76131

       Re: Medalist Diversified REIT, Inc.
           Alfred Lee Finley
           Schedule 13D filed January 29, 2025 by Alfred Lee Finley et. al
           File No. 005-90739
Dear Alfred Lee Finley:

       We have conducted a limited review of the above-captioned filing and
have the
following comments.

        Please respond to this letter by amending the filing or by providing
the requested
information. If you do not believe our comments apply to your facts and
circumstances or
that an amendment is appropriate, please advise us why in a response letter.

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

Schedule 13D filed January 29, 2025
General

1.     We note that the event reported as requiring the filing of the Schedule
13D was June
       25, 2024. Rule 13d-1(a) of Regulation 13D-G requires the filing of a
Schedule 13D
       within five business days after the date beneficial ownership of more
than five percent
       of a class of equity securities specified in Rule 13d-1(i)(1) was
acquired. Based on the
       June 25, 2024 event date, the Schedule 13D submitted on January 29, 2025
was not
       timely filed. Please advise us why the Schedule 13D was not filed within
the required
       five business days after the date of the acquisition.
2.     The cover page of the above-captioned Schedule 13D indicates that June
25, 2024 was
       the date of the event that required this filing to have been made.
Please advise us how
       this date was determined.
Item 5, page 1
 March 17, 2025
Page 2

3.     We note your disclosure that "[o]n January 28, 2025, 1,039 shares of
Common Stock
       were granted to Lee Finley by the board of directors pursuant to the
Issuer's 2018
       Equity Incentive Plan in connection with Lee Finley's service on the
board of
       directors." Item 5(c), however, requires that each beneficial owner
"describe any
       transactions in the class of securities reported on that were effected
during the past
       sixty days." Please revise to provide the requisite disclosure for each
filing person
       with respect to all transactions in the securities between the deadline
for timely filing
       the Schedule 13D and the actual filing of the Schedule 13D. In amending
the
       Schedule 13D to include the required disclosures, please be advised that
the
       Instruction to Item 5(c) requires the beneficial owner to "describe," at
a minimum, the
       following: "(1) The identity of the person covered by Item 5(c) who
effected the
       transaction; (2) the date of transaction; (3) the amount of securities
involved; (4) the
       price per share or unit; and (5) where and how the transaction was
effected."
Item 7, page 1

4.     Multiple beneficial owners have reported their beneficial ownership on
the above-
       captioned Schedule 13D. Whenever two or more persons are required to
file a
       statement containing the information required by Schedule 13D, a single
Schedule
       13D may be filed provided that it includes, as an exhibit, their
agreement in writing
       that such a statement is filed on behalf of each of them. Please revise
to add the
       required exhibit, or advise. See Rule 13d-1(k)(1)(iii).
        We remind you that the filing persons are responsible for the accuracy
and adequacy
of their disclosures, notwithstanding any review, comments, action or absence
of action by
the staff.

      Please direct any questions to Blake Grady at 202-551-8573 or Nicholas
Panos at
202-551-3266.



                                                             Sincerely,

                                                             Division of
Corporation Finance
                                                             Office of Mergers
& Acquisitions