October 9, 2019

Eliot Bencuya
Chief Executive Officer
1st stREIT Office Inc.
11601 Wilshire Boulevard
Suite 1690
Los Angeles, California 90025

       Re: 1st stREIT Office Inc.
           Post Qualification Amendment on Form 1-A
           Filed September 25, 2019
           File No. 024-10716

Dear Mr. Bencuya:

       We have reviewed your amendment and have the following comments. In some
of our
comments, we may ask you to provide us with information so we may better
understand your
disclosure.

       Please respond to this letter by amending your offering statement and
providing the
requested information. If you do not believe our comments apply 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 offering statement and the
information you
provide in response to these comments, we may have additional comments.

Post Qualification Amendment on Form 1-A filed September 25, 2019

Cover Page

1.    To the extent applicable, please reduce the amount that you are seeking
to qualify by the
      aggregate amount sold in the prior 12 month period. Refer to Rule 251(a)
of Regulation A
      and Instruction 1 to Form 1-A for guidance.
2.    We note section 13 of your Form of Subscription Agreement regarding
waiver of court
      and jury rights. Please revise your offering statement to:

        Further describe the jury trial provision, including how it will impact
your investors;

        Describe any questions as to enforceability under federal and state
law;

        Clarify whether this provision applies to claims under the federal
securities laws and
 Eliot Bencuya
1st stREIT Office Inc.
October 9, 2019
Page 2
       whether it applies to claims other than in connection with this
offering;

         To the extent the provision applies to federal securities law claims,
please revise the
       disclosure to state that by agreeing to the provision, investors will
not be deemed to have
       waived the company's compliance with the federal securities laws and the
rules and
       regulations thereunder; and

         Clarify whether purchasers of interests in a secondary transaction
would be subject to the
       jury trial waiver provision.
        We will consider qualifying your offering statement at your request. If
a participant in
your offering is required to clear its compensation arrangements with FINRA,
please have
FINRA advise us that it has no objections to the compensation arrangements
prior to
qualification.

        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 absence of
action by the staff.

       Please contact Mike Killoy at 202-551-7576 or Pam Long at 202-551-3765
with
any questions.



                                                             Sincerely,
FirstName LastNameEliot Bencuya
                                                             Division of
Corporation Finance
Comapany Name1st stREIT Office Inc.
                                                             Office of Real
Estate & Construction
October 9, 2019 Page 2
cc:       Evyn Rabinowitz
FirstName LastName