Gone through the document again. A couple of points:

1) I am glad you have included disclosure re: management partaking in repairs and rehab, although I think you still need more clarity beyond merely "We promise not to charge too much".

2) It appears that your 10% management fee comes off the top. Therefore I suggest you rephrase your definition of "net income" to include it being post management fee expense.

3)There is a good chance that the FMV per share could very well change from block #1 to #2 to #3, etc. I think you need to flesh out how exactly your secondary offerings are going to be priced. I could imagine a scenario, for example, in which you issues block#1 then over the course of 2 months the shares drift downward, at which point you issue block #2 at the suppressed levels and dilute the hell out of the existing shareholders.

4) Your "Dissolution" section is a bit weak. First, I think you should drop this buyback @110 nonsense. It is way to easy for management to abuse such a clause especially if it is not weighted or a historical average. We are not talking about a bond here. Second, it is not feasible for shares to be converted into a direct ownership stake in the RE. For a big chunk of your investors located outside of the US, it is not even legal.

I have more comments, but this is enough for now.