SecProbe.io

Mail Stop 3233

August 10, 2016

Via E -Mail
Gregg D. Adzema
Chief Financial Officer
Cousins Properties Incorporated
191 Peachtree Street , Suite 500
Atlanta, GA   30303 -1740

                 Re: Cousins Properties Incorporated
                        Form 10 -K for the Fiscal Ye ar Ended December  31, 20 15
Filed February 10, 2016
File No. 0 01-11312

Dear Mr . Adzema :

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

Please respond to these comment s within ten busine ss days by providing the
requested information or advis e us as soon as possible when you will respond.  If you do
not believe our comment s apply to your facts and circumstances,  please tell us why in
your response.

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

Item 7. Management’s Discussion and Analysis of Financial Condition an d Results of
Operations

Rental Property Net Operat ing Income , page 25

1. With respect to your presentation of NOI, please tell us ho w you considered Item
10(e)(i)(B ) of Regulation S -K which requires a reconciliation of non -GAAP
financial measures disclosed or released with the most directly comparable
financial measure or measures calculated and presented in accordance with
GAAP.

Gregg D. Adzema
Cousins Properties Incorporated
August 10, 2016
Page 2

 Note 17. Reportable Segments, page F -26

2. We note that your reportable segments are classif ied by property type and
geographical area and their performance is evaluated based on NOI which
represents rental property revenues less rental property operating expenses. We
also note that you have disclosed NOI by property type and geographical area bu t
no rental property revenues.  Please tell us how you considered ASC 280 -10-50-
22 which requires disclosure of revenues for each reportable segment if those
amounts are included in the measure of segment profit or loss reviewed by the
chief operating deci sion maker .

We urge all persons who are responsible for the accuracy and adequacy of the
disclosure in the filing to be certain that the filing includes the information the Securities
Exchange Act of 1934 and all applicable Exchange Act rules require.   Since the company
and its management are in possession of all facts relating to a company’s disclosure, they
are responsible for the accuracy and adequacy of the disclosures they have made.

 In responding to our comment, please provide a written statement from the
company acknowledging that:

 the company is responsible for the adequacy and accuracy of the disclosure in the
filing;

 staff comments or changes to disclosure in response to staff comments do not
foreclose the Commission from taking any action with respect to the filing; and

 the company may not assert staff comments as a defense in any proceeding
initiated by the Commission or any person under the federal securities laws of the
United States.

You may contact Jorge L. Bonilla , Staff Accountant  at (202) 551 -3414 or me at
(202) 551 -3856 with any questions.

                                                                                    Sincerely,

        /s/ Shannon Sobotka

Shannon Sobotka
                                                                         Staff Accountant
                                                                                                Office of Real Estate and
                                                                                                Commodities