UNITED STATES
                                  SECURITIES AND EXCHANGE COMMISSION
                                              WASHINGTON, D.C. 20549


    DIVISION OF
CORPORATION FINANCE


                                                                       March
16, 2020


 Ziv Sapir
 Comrit Investments 1, LP
 9 Ahad Ha'am Street
 Tel Aviv, Israel 6129101

         Re:     Healthcare Trust, Inc.
                 Schedule TO-T/A
                 Filed March 10, 2020 by Comrit Investments 1, Limited
Partnership
                 File No. 005-89596

 Dear Mr. Sapir:

         We have reviewed the above-captioned filing, and have the following
comments. Please
 respond by replying in writing to this letter and providing us with any
requested additional
 information and/or amending the filing. If you do not believe a comment
applies to your facts
 and circumstances and/or do not believe an amendment is appropriate, please
advise us why.

        After reviewing any amendment to the filing and any information
provided in response to
 these comments, we may have additional comments.

 Schedule TO-T/A

 1. The offer has been conditioned upon their not having been "any general
suspension of
    trading in, or limitation on prices for, securities on any national
securities exchange or in the
    over-the-counter market in the United States..." Given that shares in the
subject company
    for which the offer has been made are not traded on a national securities
exchange, please
    advise us, with a view toward revised disclosure, of the purpose of this
language.

 2. Please advise us, with a view toward revised disclosure, whether or not the
language derived
    from the above-cited condition appearing in Section 12(d) of the Offer to
Purchase has
    become operative. We note, for example, that multiple temporary cessations
in trading have
    been implemented on the New York Stock Exchange as a result of compliance
with
    compulsory trading curbs since the offer has commenced.

 3. To the extent the offerors conclude that a "general suspension of trading"
has occurred,
    please advise us, with a view toward revised disclosure, whether or not the
condition has
    been waived or a decision has been made to terminate the offer. Please also
advise us
    whether or not a material change has occurred under Rules 14d-6(c),
14d-3(b)(1) and 14d-
    4(d)(1), and if so, how the offerors intend to effectuate compliance with
those rules.
 Ziv Sapir
Comrit Investments 1, LP
March 16, 2020
Page 2


                                        *       *      *

       We remind you that the offerors are responsible for the accuracy and
adequacy of its
disclosures, notwithstanding any review, comments, action or absence of action
by the staff.

        You may contact me at (202) 551-3266 with any questions.


                                                           Sincerely,

                                                           /s/ Nicholas P.
Panos

                                                           Nicholas P. Panos
                                                           Senior Special
Counsel
                                                           Office of Mergers &
Acquisitions

cc:    Amos W. Barclay, Esq.