UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549 DIVISION OF CORPORATION FINANCE September 24, 2018 Via Email Michael J. Choate Proskauer Rose LLP Three First National Plaza 70 West Madison Suite 3800 Chicago, IL 60602-4342 Re: Inland Real Estate Income Trust, Inc. Schedule 14D-9 filed September 21, 2018 SEC File No. 5-90632 Dear Mr. Choate: The staff in the Office of Mergers and Acquisitions in the Division of Corporation Finance has reviewed the filing listed above. Our comment follows. All defined terms have the same meaning as in your filing, unless otherwise noted. Please respond to this letter promptly by amending your filing. If you do not believe our comment applies to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response. After reviewing any amendment to your filing and the information you provide in response to this letter, we may have additional comments. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure. Please allow sufficient time for additional staff review after filing your revised offer materials and your response letter. Item 4. The Solicitation or Recommendation 1. We note the disclosure on page 5 of the Schedule 14D-9 stating that on September 5, 2018, the Board authorized management to investigate converting the Company into a perpetual-life NAV REIT. Explain specifically why the Board believes this would Michael J. Choate, Esq. Proskauer Rose LLP September 24, 2018 Page 2 increase the long-term value of the Company and how and why it factored into the Board's decision to reject the Tender Offer. 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 contact me at (202) 551-3263 with any questions about this comment. Sincerely, /s/ Christina Chalk Christina Chalk Senior Special Counsel Office of Mergers and Acquisitions