Although the complex will have 100,000 square feet of space when completed, tenants can lease as little as 800 feet.
Section 6 allows a tenant for life to lease the land or any part of it.
A single tenant, Stuart Olson Dominion Construction, leased the entire building.
The new tenant said she would live on the top three floors but lease the ground floor and part of the basement to a retailer.
After the purchase, he instructed William Russell, a friend already living in Kentucky, to find tenants to lease and improve the land.
The tenant is leasing 350,000 square feet.
By the end of 1938, 35 new tenants had signed leases and 11 existing tenants had leased additional space in the building.
Ten tenants have leased 80 percent of the space, including national retailers like the Gap and Walgreens.
Under each plan construction will start once a tenant has leased space.
Thirteen tenants, including a delicatessen and a dentist, have been leasing 38,000 square feet, paying annual rents ranging from $11.41 to $18.49 a square foot.