SecProbe.io

March 15, 2012
 VIA E-Mail

Mr. Howard M. Sipzner Executive Vice President and Chief Financial Officer Brandywine Realty Trust 555 East Lancaster Avenue Radnor, Pennsylvania 19087

Re: Brandywine Realty Trust
  Form 10-K for the year  ended December 31, 2011
Filed on February 24, 2012 File No. 001-09106  Brandywine Operating Partnership, L.P.
Form 10-K for the year ended December 31, 2011
Filed on February 24, 2012 File No. 000-24407

Dear Mr. Howard M. Sipzner:
We have limited our review to only your fina ncial statements and related disclosures and
do not intend to expand our review to other porti ons of your documents.   In our comments, we
may ask you to provide us with informati on so we may better understand your disclosure.

Please respond to this letter within te n business days by providing the requested
information or by advising us when you will provide the requested response. If you do not believe our comments apply to your facts and circum stances, please tell us why in your response.

 After reviewing the information you provide  in response to these comments, we may
have additional comments.  FORM 10-K  FOR THE YEAR  ENDED DECEMBER 31, 2011

 Results Of Operations, page 46

Mr. Howard M. Sipzner Brandywine Realty Trust Brandywine Operating Partnership, L.P. March 15, 2012 Page 2

 1. We note your presentation of same store prope rty portfolio information.   In future
periodic filings please expand to disclose and discuss the following.

 Expand upon your existing definition of same store to discuss at what point in the
development or redevelopment process you exclude them from your same store designation.
 Include in your same store disclosures occupancy and averag e rent trends, as
adjusted for leasing incentives if any
 2. Please revise future periodic filings to clarify what expenses are included in property
operating expenses and what expenses are included in general and administrative
expenses. Within your response, please provi de an example of your proposed disclosure.
 Notes to Consolidated Financial Statements

 Summary of Significan t Accounting Policies

 Depreciation and Amortization, page F-20

3. Please provide to us your mate riality analysis supporting ma nagement’s opinion that the
correction of the error was not material to the financial statements presented.  Within your response, please ensure that you specifi cally address the larg e percentage of the
2011 net loss the correction of the error represents.
   We urge all persons who are responsible fo r the accuracy and adequ acy of the disclosure
in the filing to be certain that the filing include s the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules requir e. 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 comments, please provi de a written statement from the company
acknowledging that:
 the company is responsible for the adequacy an d accuracy of the disclo sure in the filings;

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

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

Mr. Howard M. Sipzner Brandywine Realty Trust Brandywine Operating Partnership, L.P. March 15, 2012 Page 3

 You may contact Wilson K. Lee at (202) 551-3468 or me at (202) 551-3629 if you have
any questions.

                                                                     Sincerely,
   /s/ Kevin Woody
          K e v i n  W o o d y           B r a n c h  C h i e f