United States securities and exchange commission logo March 3, 2023 Troy B. Steckenrider III Chief Financial Officer two 900 Kearny St., Suite 610 San Francisco, CA 94133 Re: two Preliminary Proxy Statement on Schedule 14A Filed February 17, 2023 File No. 001-40292 Dear Troy B. Steckenrider III: 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 cc: Niral Shah, Esq.