August 9, 2019

Dave Guiteau
Chief Financial Officer
Starwood Real Estate Income Trust, Inc.
1601 Washington Avenue
Suite 800
Miami Beach, FL 33139

       Re: Starwood Real Estate Income Trust, Inc.
           Form 10-K for the Fiscal Year Ended December 31, 2018
           Filed March 28, 2019
           File No. 333-220997
           Form 10-Q for the Quarter Ended March 31, 2019
           Filed May 14, 2019
           File No. 000-56046

Dear Mr. Guiteau:

        We have limited our review of your filing to the financial statements
and related
disclosures and have the following comment. In our comment, we may ask you to
provide us
with information so we may better understand your disclosure.

       Please respond to this comment within ten business days by providing the
requested
information or advise us as soon as possible when you will respond. If you do
not believe our
comment applies to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to this comment, we may have additional
comments.

Form 10-Q for the Quarter Ended March 31, 2019

Net Asset Value, page 25

1.    We note that you have acquired real estate investments that are material
to your
      calculation of NAV. Please confirm to us that you will include a
description of your
      valuation guidelines for these investments in future periodic filings
when material changes
      in NAV are reported. The disclosure should include primary valuation
method(s) and key
      assumptions used to determine the fair value of the investments.

       In closing, we remind you that the company and its management are
responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review,
comments, action or
 Dave Guiteau
Starwood Real Estate Income Trust, Inc.
August 9, 2019
Page 2

absence of action by the staff.

       You may contact Isaac Esquivel at (202) 551-3395 or Kristi Marrone at
(202) 551-3429
with any questions.



                                                         Sincerely,
FirstName LastNameDave Guiteau
                                                     Division of Corporation
Finance
Comapany NameStarwood Real Estate Income Trust, Inc.
                                                     Office of Real Estate and
August 9, 2019 Page 2                                Commodities
FirstName LastName