Gregory W. Preston, Esq.
Managing Director
Corporate Law Solutions, PC
907 Sandcastle Drive
Corona del Mar, CA 92625
Direct: 949.760.0107
Fax: 949.760.0107
Email: gpreston@corp-law.com
October 22, 2014
Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549
Attention: Kristina Aberg, Esq.
Jerard Gibson, Esq.
Re: DSI Realty Income Fund VI, VII, VIII, IX, X, and XI
Preliminary Proxy Statements on Schedule 14A
Filed September 23, 2014
File Nos. 002-68926, 002-83291, 002-90168, 000-14186, 000-15346, and
000-18286
Ladies and Gentlemen:
On behalf of DSI Realty Income Funds VI through XI (the “Funds”), this letter is written in response to your comment letter dated October 22, 2014 and the numbered responses below correspond to the numbered comments in that letter.
| 1. | In your letter you state that Proposal items 1-3 each contain multiple matters for Limited Partner approval. By way of example, you stated that Proposal item 2 seeks approval of the sale of the propertiesand the payment of fees payable under the limited partnership agreement. |
However, the only approval being sought in Proposal item 2 is approval of the distribution of the net proceeds from the sale of all of the properties. The item provides Limited Partner disclosures as to the estimated per Unit amount of those net proceeds and how that amount was derived from the aggregate gross purchase being paid for the properties. The payment of the fees under the partnership agreement is already authorized; therefore, no Limited Partner consent is required for those payments.
Likewise, Proposal item 3 seeks only the approval of such lesser amount as may be determined in the event that less than all of the properties are sold; and Proposal item 1 seeks only the approval of the Purchase and Sale Agreement.
| 2. | Please be advised that the Funds did not receive any reports, opinions or appraisals from Bancap Self Storage Group, Inc. or any other third party. |
Securities and Exchange Commission
DSI Realty Income Fund VI, VII, VIII, IX, X, and XI
October 22, 2014
Page 2
On behalf of the Funds, the following acknowledgements are hereby provided:
| · | the Funds are responsible for the adequacy and accuracy of the disclosure in their respective filing; |
| · | staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to their filings; and |
| · | the Funds may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. |
Please advise us at you earliest convenience that the responses and acknowledgements provided herein are sufficient or if you require anything further before the Funds can file their definitive proxy statements.
Very truly yours,
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Corporate Law Solutions, PC
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| By /s/GREGORY W. PRESTON | |
| Gregory W. Preston, Esq | |
| Managing Director |