United States securities and exchange commission logo August 2, 2023 Larry Finger Principal Financial Officer Copper Property CTL Pass Through Trust 3 Second Street, Suite 206 Jersey City, NJ 07311-4056 Re: Copper Property CTL Pass Through Trust Amendment No. 1 to Form 10-K for the Period Ended December 31, 2022 Filed May 2, 2023 File No. 000-56236 Dear Larry Finger: 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