| 330 North Wabash Avenue | ||||||||||
| Suite 2800 | ||||||||||
| Chicago, Illinois 60611 | ||||||||||
| Tel: +1.312.876.7700 Fax: +1.312.993.9767 | |||||||||
| www.lw.com | ||||||||||
| FIRM / AFFILIATE OFFICES | ||||||||||
| Barcelona | Moscow | |||||||||
| Beijing | Munich | |||||||||
| Boston | New York | |||||||||
| Brussels | Orange County | |||||||||
| November 27, 2017 | Century City | Paris | ||||||||
| Chicago | Riyadh | |||||||||
| VIA EDGAR | Dubai | Rome | ||||||||
| Düsseldorf | San Diego | |||||||||
| Frankfurt | San Francisco | |||||||||
Robert F. Telewicz, Jr. Accounting Branch Chief Office of Real Estate and Commodities U.S. Securities and Exchange Commission 100 F Street, N.E., Mailstop 3233 Washington, D.C. 20549 | Hamburg | Seoul | ||||||||
| Hong Kong | Shanghai | |||||||||
| Houston | Silicon Valley | |||||||||
| London | Singapore | |||||||||
| Los Angeles | Tokyo | |||||||||
| Madrid | Washington, D.C. | |||||||||
| Milan | ||||||||||
| Re: | Highlands REIT, Inc. |
| Form10-K for the year ended December 31, 2016 |
| Filed on March 27, 2017 |
| FileNo. 000-55580 |
Dear Mr. Telewicz:
On behalf of Highlands REIT, Inc. (“Highlands”), we submit this letter in response to the comment and request for additional information contained in the letter (the “Comment Letter”) from the staff of the Office of Real Estate and Commodities (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”), dated November 13, 2017. The Comment Letter relates to Highland’s Form10-K for the year ended December 31, 2016, filed March 27, 2017.
For your convenience, we have repeated the comment of the Staff in italicized text exactly as given in the Comment Letter and set forth our response below such comment.
Staff Comment
FORM10-K FOR THE YEAR ENDED DECEMBER 31, 2016
Results of Operations, pages 39 – 42
| 1. | We note your results of operations only discuss a comparison of the two most recent fiscal periods ended December 31, 2016 and 2015. Please clarify your basis for not including a discussion that covers the three-year period covered by the financial statements presented pursuant to Instructions to paragraph 303(a) of RegulationS-K. Please explain and/or revise future periodic filings accordingly. |
Response:
In response to the Staff’s comment, Highlands will include a discussion that covers the three-year period covered by the financial statements presented pursuant to the Instructions to paragraph 303(a) of RegulationS-K in future filings with the Commission.
* * * *
Once you have had time to review our response to the Staff’s comments, we would appreciate the opportunity to discuss any additional questions or concerns that you may have. Please feel free to contact me by telephone at(312) 876-7681.
November 27, 2017
Page 2
Sincerely, |
| /s/ Cathy A. Birkeland |
Cathy A. Birkeland of Latham & Watkins LLP |
| cc: | Richard Vance, Highlands REIT, Inc. |
Robert J. Lange, Esq., Highlands REIT, Inc.
Joseph Giannini, Highlands REIT, Inc.