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                             September 20, 2021

       Catherine Hastings
       Chief Financial Officer
       Innovative Industrial Properties, Inc.
       1389 Center Drive, Suite 200
       Park City, UT 84098

                                                        Re: Innovative
Industrial Properties, Inc.
                                                            Form 10-K for the
year ended December 31, 2020
                                                            Filed February 26,
2021
                                                            File No. 001-37949

       Dear Ms. Hastings:

              We have reviewed your filing 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 these comments 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
       comments apply to your facts and circumstances, please tell us why in
your response.

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

       Form 10-K for the year ended December 31, 2020

       Management's Discussion and Analysis of Financial Condition and Results
of Operations
       Acquisition of Rental Property, Depreciation and Impairment, page 65

   1.                                                   We note that you
capitalize and depreciate tenant improvements when you are considered
                                                        to be the owner of such
improvements over the estimated useful lives of the
                                                        improvements, not to
exceed 40 years. Please expand your disclosure to explain how you
                                                        determine whether you
or the tenant is the owner of the improvements, citing relevant
                                                        accounting literature.
In addition, please tell us how you considered ASC 842-10-35-6 in
                                                        determining the
amortization period of tenant improvements.
       Note 2. Summary of Significant Accounting Policies and Procedures and
Recent Accounting
       Pronouncements
       Revenue Recognition, page F-9

   2.                                                   We note that you record
revenue for each of your properties on a cash basis due to the
 Catherine Hastings
Innovative Industrial Properties, Inc.
September 20, 2021
Page 2
         uncertain regulatory environment in the United States relating to the
medical-use cannabis
         industry and the uncertainty of collectability of lease payments from
each tenant due to its
         limited operating history. Please provide us with a more in-depth
understanding of how
         you determined that collection of lease payments was not probable from
any of your
         tenants at lease inception and whether or not you perform
reassessments of collectability
         after the lease commencement date. Refer to ASC 842-30-25-12 and 13.
        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 William Demarest, Staff Accountant at 202-551-3432 or
Kristina
Marrone, Staff Accountant at 202-551-3429 if you have any questions.



FirstName LastNameCatherine Hastings                           Sincerely,
Comapany NameInnovative Industrial Properties, Inc.
                                                               Division of
Corporation Finance
September 20, 2021 Page 2                                      Office of Real
Estate & Construction
FirstName LastName