October 24, 2019

George P. Doyle
Chief Financial Officer
Landmark Infrastructure Partners LP
400 Continental Boulevard
Suite 500
P.O. Box 3429
El Segundo, CA 90245

       Re: Landmark Infrastructure Partners LP
           Form 10-K for the Fiscal Year Ending December 31, 2018
           Filed February 20, 2019
           File No. 001-36735

Dear Mr. Doyle:

       We have limited our review of your filing to the financial statements
and related
disclosures and have the following comments. In some of our comments, we may
ask you to
provide us with information so we may better understand your disclosure.

       Please respond to these comments within ten business days by providing
the requested
information or advise us as soon as possible when you will respond. If you do
not believe our
comments apply to your facts and circumstances, please tell us why in your

       After reviewing your response to these comments, we may have additional

Form 10-K for the Fiscal Year Ending December 31, 2018

EBITDA, Adjusted EBITDA and Distributable Cash Flow, page 52

1.    We note that your calculation of EBITDA contains an adjustment for items
other than
      interest, taxes, depreciation and amortization. Please revise future
filings to ensure that
      measures calculated differently from EBITDA are not characterized as
      Reference is made to Question 103.01 of the Division s Compliance and
      Interpretations for Non-GAAP Financial Measures. This comment also
applies to your
      future earnings releases and future supplemental packages.
Funds from Operations ("FFO") and Adjusted Funds from Operations ("AFFO"), page

2.    We note that your calculation of FFO makes adjustments for distributions
to preferred
      unitholders and noncontrolling interests. Therefore, it appears that FFO
is attributable to
 George P. Doyle
Landmark Infrastructure Partners LP
October 24, 2019
Page 2
         common and subordinated unitholders. Please clarify and/or revise the
labeling of your
         non-GAAP financial measure in future filings to adequately reflect
what is being
         presented. This comment also applies to your future earnings releases
and future
         supplemental packages.
Notes to Consolidated and Combined Financial Statements
Note 8. Investment in Unconsolidated Joint Venture, page F-22

3.       We note that you recognized a gain on contribution of real property
interests to an
         unconsolidated JV since you determined that you do not have a
controlling financial
         interest in the entity that holds the assets. Please provide us with a
detailed analysis of
         how you reached your conclusion, given that you maintain an ownership
level in excess of
         50%. Cite relevant accounting literature in your response.
       In closing, 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.

       You may contact Isaac Esquivel at (202) 551-3395 or Kristi Marrone at
(202) 551-3429
with any questions.

FirstName LastNameGeorge P. Doyle                             Sincerely,
Comapany NameLandmark Infrastructure Partners LP
                                                              Division of
Corporation Finance
October 24, 2019 Page 2                                       Office of Real
Estate & Construction
FirstName LastName