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 May 12, 2025

Gregg D. Adzema
Chief Financial Officer
Cousins Properties Inc.
3344 Peachtree Road NE, Suite 1800
Atlanta, GA 30326

 Re: Cousins Properties Inc.
 Form 10-K for the fiscal year ended December 31, 2024
 File No. 001-11312
Dear Gregg D. Adzema:

 We have reviewed your filing and have the following comments.

 Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in your
response.

 After reviewing your response to this letter, we may have additional
comments.

Annual Report on Form 10-K
Properties , page 21

1. We note you disclose total annualized rent on page 22. Please tell us
and revise future
 filings to disclose your average effective annual rent per square foot
and add footnote
 disclosure to clarify how the average effective rent takes into account
all tenant
 concessions, not just free rent. We note you disclose the weighted
average net
 effective rent per square foot for new or renewed non-amenity leases in
2024 on page
 29.
2. We note the references in this section and in your MD&A to your
properties being
 stabilized. In future Exchange Act periodic reports, please tell us what
management
 considers in determining whether a property is not yet stabilized.
Management's Discussion and Analysis of Financial Condition and Results of
Operations,
page 29

3. We note your disclosure on page 29 that the weighted average net
effective rent per
 square foot, representing base rent excluding operating expense
reimbursements and
 leasing costs, for new or renewed non-amenity leases with terms greater
than one year
 May 12, 2025
Page 2

 signed in 2024, was $28.17 per square foot. In future Exchange Act
periodic reports,
 please discuss leasing results for the prior period, including the
amount of leases that
 were new leases compared to renewal leases, and the amount of leases
that were not
 renewed. Additionally, this disclosure should include a discussion of
tenant
 improvement costs, leasing commissions, and tenant concessions. Further,
please
 quantitatively discuss the relationship between expiring rents and
current market
 rents.
4. We note the disclosure on page 30 regarding how you recognize revenue
when the
 lease provides the tenant with an extension or early termination option.
Please tell us
 and revise future filings to clarify the percentage of your occupied
properties that have
 tenants with early termination provisions and discuss the impact to you
from tenants
 exercising such provisions, including the number of tenants that have
exercised that
 provision over the past two years and the amount of impacted square
footage.

5. We note your goal of maintaining a portfolio of newer and more efficient
properties
 and that your portfolio consists primarily of lifestyle office
buildings. Please clarify
 what you mean by newer and more efficient properties and lifestyle
office buildings.
 Please tell us, and in future filings, please clarify, if the type of
property or
 office building is impacting your ability to renew leases, or obtain new
tenants, and
 the impact on leasing costs associated with renewing or re-letting a
particular space.
 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.

 Please contact Jeffrey Lewis at 202-551-6216 or Shannon Menjivar at
202-551-3856
if you have questions regarding comments on the financial statements and
related
matters. Please contact Ruairi Regan at 202-551-3269 or Pam Howell at
202-551-3357 with
any other questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Real
Estate & Construction
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