United States securities and exchange commission logo March 8, 2022 Brian Mitts Chief Financial Officer VineBrook Homes Trust, Inc. 2515 McKinney Avenue, Suite 1100 Dallas, TX 75201 Re: VineBrook Homes Trust, Inc. Registration Statement on Form 10-12G Filed April 30, 2021 File No. 000-56274 Dear Mr. Mitts: We have completed our review of your filing. 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. Sincerely, Division of Corporation Finance Office of Real Estate & Construction