March 30, 2020

Jeffrey Taylor
Managing Director
Black Creek Diversified Property Fund Inc.
518 Seventeenth Street, 17th Floor
Denver, CO 80202

       Re: Black Creek Diversified Property Fund Inc.
           Post-Effective Amendment to Form S-11
           Filed March 19, 2020
           File No. 333-222630

Dear Mr. Taylor:

       We have reviewed your post-effective amendment 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 letter by amending your registration statement
and providing the
requested information. 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 registration statement and the
information you
provide in response to this comment, we may have additional comments.

Post-Effective Amendment No. 21 to Registration Statement on Form S-11 filed
March 19, 2020

Forum for Certain Litigation, page 213

1.     We note that your forum selection provision identifies the Circuit Court
for Baltimore
       City, Maryland as the exclusive forum for certain litigation, including
any "derivative
       action." Please disclose whether this provision applies to actions
arising under the
       Securities Act or Exchange Act. In that regard, we note that Section 27
of the Exchange
       Act creates exclusive federal jurisdiction over all suits brought to
enforce any duty or
       liability created by the Exchange Act or the rules and regulations
thereunder, and Section
       22 of the Securities Act creates concurrent jurisdiction for federal and
state courts over all
       suits brought to enforce any duty or liability created by the Securities
Act or the rules and
       regulations thereunder. If the provision applies to Securities Act
claims, please also revise
       your prospectus to state that there is uncertainty as to whether a court
would enforce such
 Jeffrey Taylor
Black Creek Diversified Property Fund Inc.
March 30, 2020
Page 2
         provision and that investors cannot waive compliance with the federal
securities laws and
         the rules and regulations thereunder.
        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.

       You may contact Jonathan Burr at 202-551-5833 or James Lopez at
202-551-3536 with
any questions.



FirstName LastNameJeffrey Taylor                      Sincerely,
Comapany NameBlack Creek Diversified Property Fund Inc.
                                                      Division of Corporation
Finance
March 30, 2020 Page 2                                 Office of Real Estate &
Construction
FirstName LastName