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Filing Details

Accession Number:: 0001104659-25-011409
Form Type:: 13G Filing
Publication Date:: 2025-02-10 19:00:00

Filed By:: Comrit Investments 1, Limited Partnership
Company:: Pacific Oak Strategic Opportunity Reit Inc.
Filing Date:: 2025-02-11
SEC Url:: 13G Filing

Ownership Summary

Please notice the below summary table is generated without human intervention and may contain errors. Please refer to the complete filing displayed below for exact figures.

Name	Beneficially Owned Number of Aggregate Shares	Percent of Class
Comrit Investments 1, Limited Partnership	5,334,318	5.2%
Comrit Investments Ltd.	5,334,318	5.2%
Ziv Sapir	5,334,318	5.2%

Filing

SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549

SCHEDULE 13G

UNDER THE SECURITIES EXCHANGE ACT OF 1934

Pacific Oak Strategic Opportunity REIT, Inc.

(Name of Issuer)

Common Stock, $0.01 Par Value

(Title of Class of Securities)

694701103

(CUSIP Number)

12/31/2024

(Date of Event Which Requires Filing of this Statement)

Check the appropriate box to designate the rule pursuant to which this Schedule is filed:

Rule 13d-1(b)

Rule 13d-1(c)

Rule 13d-1(d)

SCHEDULE 13G

CUSIP No.

694701103

Names of Reporting Persons

Comrit Investments 1, Limited Partnership

Check the appropriate box if a member of a Group (see instructions)

(a)

(b)

Sec Use Only

Citizenship or Place of Organization

CAYMAN ISLANDS

Number of Shares Beneficially Owned by Each Reporting Person With:

5	Sole Voting Power 5,334,318.82
6	Shared Voting Power 0.00
7	Sole Dispositive Power 5,334,318.82
8	Shared Dispositive Power 0.00

Aggregate Amount Beneficially Owned by Each Reporting Person

5,334,318.82

Check box if the aggregate amount in row (9) excludes certain shares (See Instructions)

Checkbox not checked

Percent of class represented by amount in row (9)

5.2 %

Type of Reporting Person (See Instructions)

Comment for Type of Reporting Person: Percent of class is based on 102,951,395 shares of common stock issued and outstanding as of November 6, 2024, as reported by Pacific Oak Strategic Opportunity REIT, Inc. in its Form 10-Q for the quarterly period ended September 30, 2024.

SCHEDULE 13G

CUSIP No.

694701103

Names of Reporting Persons

Comrit Investments Ltd.

Check the appropriate box if a member of a Group (see instructions)

(a)

(b)

Sec Use Only

Citizenship or Place of Organization

ISRAEL

Number of Shares Beneficially Owned by Each Reporting Person With:

5	Sole Voting Power 5,334,318.82
6	Shared Voting Power 0.00
7	Sole Dispositive Power 5,334,318.82
8	Shared Dispositive Power 0.00

Aggregate Amount Beneficially Owned by Each Reporting Person

5,334,318.82

Check box if the aggregate amount in row (9) excludes certain shares (See Instructions)

Checkbox not checked

Percent of class represented by amount in row (9)

5.2 %

Type of Reporting Person (See Instructions)

SCHEDULE 13G

CUSIP No.

694701103

Names of Reporting Persons

Ziv Sapir

Check the appropriate box if a member of a Group (see instructions)

(a)

(b)

Sec Use Only

Citizenship or Place of Organization

ISRAEL

Number of Shares Beneficially Owned by Each Reporting Person With:

5	Sole Voting Power 5,334,318.82
6	Shared Voting Power 0.00
7	Sole Dispositive Power 5,334,318.82
8	Shared Dispositive Power 0.00

Aggregate Amount Beneficially Owned by Each Reporting Person

5,334,318.82

Check box if the aggregate amount in row (9) excludes certain shares (See Instructions)

Checkbox not checked

Percent of class represented by amount in row (9)

5.2 %

Type of Reporting Person (See Instructions)

SCHEDULE 13G

Item 1.

(a)

Name of issuer:

Pacific Oak Strategic Opportunity REIT, Inc.

(b)

Address of issuer's principal executive offices:

11766 Wilshire Blvd, Suite 1670 Los Angeles, CA, 90025

Item 2.

(a)

Name of person filing:

(i) Comrit Investments 1, Limited Partnership, a Cayman Islands exempted limited partnership; (ii) Comrit Investments Ltd., an Israel limited liability private company; and (iii)Ziv Sapir, an Israeli citizen.

(b)

Address or principal business office or, if none, residence:

9 Ahad Ha'am Street Tel Aviv, Israel 6129101

(c)

Citizenship:

Comrit Investments 1, Limited Partnership - Cayman Islands Comrit Investments Ltd. - Israel Ziv Sapir - Israel

(d)

Title of class of securities:

Common Stock, $0.01 Par Value

(e)

CUSIP No.:

694701103

Item 3.

If this statement is filed pursuant to §§ 240.13d-1(b) or 240.13d-2(b) or (c), check whether the person filing is a:

(a)

Broker or dealer registered under section 15 of the Act (15 U.S.C. 78o);

(b)

Bank as defined in section 3(a)(6) of the Act (15 U.S.C. 78c);

(c)

Insurance company as defined in section 3(a)(19) of the Act (15 U.S.C. 78c);

(d)

Investment company registered under section 8 of the Investment Company Act of 1940 (15 U.S.C. 80a-8);

(e)

An investment adviser in accordance with § 240.13d-1(b)(1)(ii)(E);

(f)

An employee benefit plan or endowment fund in accordance with § 240.13d-1(b)(1)(ii)(F);

(g)

A parent holding company or control person in accordance with § 240.13d-1(b)(1)(ii)(G);

(h)

A savings associations as defined in Section 3(b) of the Federal Deposit Insurance Act (12 U.S.C. 1813);

(i)

A church plan that is excluded from the definition of an investment company under section 3(c)(14) of the Investment Company Act of 1940 (15 U.S.C. 80a-3);

(j)

A non-U.S. institution in accordance with § 240.13d-1(b)(1)(ii)(J). If filing as a non-U.S. institution in accordance with § 240.13d-1(b)(1)(ii)(J),
please specify the type of institution:

(k)

Group, in accordance with Rule 240.13d-1(b)(1)(ii)(K).

Item 4.

Ownership

(a)

Amount beneficially owned:

For Comrit Investments 1, Limited Partnership: 5,334,318.82 For Comrit Investments Ltd: 5,334,318.82 For Ziv Sapir: 5,334,318.82

(b)

Percent of class:

For Comrit Investments 1, Limited Partnership: 5.2% For Comrit Investments Ltd: 5.2% For Ziv Sapir: 5.2%

(c)

Number of shares as to which the person has:

(i) Sole power to vote or to direct the vote:

For Comrit Investments 1, Limited Partnership: 5,334,318.82 For Comrit Investments Ltd: 5,334,318.82 For Ziv Sapir: 5,334,318.82

(ii) Shared power to vote or to direct the vote:

For Comrit Investments 1, Limited Partnership: 0 For Comrit Investments Ltd: 0 For Ziv Sapir: 0

(iii) Sole power to dispose or to direct the disposition of:

For Comrit Investments 1, Limited Partnership: 5,334,318.82 For Comrit Investments Ltd: 5,334,318.82 For Ziv Sapir: 5,334,318.82

(iv) Shared power to dispose or to direct the disposition of:

For Comrit Investments 1, Limited Partnership: 0 For Comrit Investments Ltd: 0 For Ziv Sapir: 0

Item 5.

Ownership of 5 Percent or Less of a Class.

Item 6.

Ownership of more than 5 Percent on Behalf of Another Person.

Not Applicable

Item 7.

Identification and Classification of the Subsidiary Which Acquired the Security Being Reported on by the Parent Holding Company or Control Person.

Not Applicable

Item 8.

Identification and Classification of Members of the Group.

Not Applicable

Item 9.

Notice of Dissolution of Group.

Not Applicable

Item 10.

Certifications:

By signing below I certify that, to the best of my knowledge and belief, the securities referred to above were not acquired and are not held for the purpose of or with the effect of changing or influencing the control of the issuer of the securities and were not acquired and are not held in connection with or as a participant in any transaction having that purpose or effect, other than activities solely in connection with a nomination under ?? 240.14a-11.

SIGNATURE

After reasonable inquiry and to the best of my knowledge and belief, I certify that the information set forth in this statement is true, complete and correct.

Comrit Investments 1, Limited Partnership

Signature:	/s/ Ziv Sapir
Name/Title:	Ziv Sapir / Chief Executive Officer
Date:	02/11/2025

Comrit Investments Ltd.

Signature:	/s/ Ziv Sapir
Name/Title:	By Comrit Investments Ltd., its general partner Ziv Sapir / Chief Executive Officer
Date:	02/11/2025

Ziv Sapir

Signature:	/s/ Ziv Sapir
Name/Title:	Ziv Sapir
Date:	02/11/2025

Exhibit Information

Exhibit 1: Joint Filing Agreement, dated as of February 11, 2025, by and between Comrit Investments Ltd., Comrit Investments 1, Limited Partnership, and Ziv Sapir, as required by Rule 13d-1(k)(1) under the Securities Exchange Act of 1934, as amended.