SecProbe.io

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<FILENAME>filename1.txt
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Mail Stop 4561
      August 16, 2005

VIA U.S. MAIL AND FAX (615) 269-8461

Mr. Scott W. Holmes
Senior Vice President and Chief Financial Officer
Healthcare Realty Trust Incorporated
3310 West End Avenue
Suite 700
Nashville, TN  37203

      Re:	Healthcare Realty Trust, Inc.
      Item 4.01 Form 8-K/A
      Filed July 11, 2005
      File No. 1-11852

Dear Mr. Holmes:

      We have reviewed your response letter and amendment dated
July
11, 2005 and have the following additional comments.  As
previously
stated, these comments require amendment to the referenced filings
previously filed with the Commission.  Where indicated, we think
you
should revise your document in response to these comments.  If you
disagree, we will consider your explanation as to why our comment
is
inapplicable or a revision is unnecessary.  Please be as detailed
as
necessary in your explanation.  In one of our comments, we ask you
to
provide us with supplemental information so we may better
understand
your disclosure.  After reviewing this information, we may raise
additional comments.

      	Please understand that the purpose of our review process
is
to assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.

Form 8-K/A filed July 11, 2005

1. We note your response to prior comment 1.  With respect to the
Item 4.01 8-K/A filed on July 11, 2005, please file a revised
Exhibit
16 letter in accordance with Item 304(a)(3) of Regulation S-K.

2. We note your response to prior comment 2 and your statements
that
"the company considers the assertions contained in the letter
regarding the company`s financial management to be unfounded" and
that the letter "contains material factual inaccuracies which may
have led to KPMG LLP`s erroneous conclusion."  Please tell us why
you
consider KPMG`s assertions about management to be unfounded,
describe
the factual inaccuracies mentioned and tell us why you believe
that
KPMG came to an erroneous conclusion.  Additionally, tell us how
this
does not represent a disagreement with your accountant as defined
in
Item 304(a)(1)(iv) of Regulation S-K.

      As appropriate, please amend your filing and respond to
these
comments within five business days or tell us when you will
respond.
You may wish to provide us with marked copies of the amendment to
expedite our review.  Please furnish a cover letter with your
amendment that keys your responses to our comments and provides
any
requested information.  Detailed cover letters greatly facilitate
our
review.  Please understand that we may have additional comments
after
reviewing your amendment and responses to our comments.

      Any questions regarding the above should be directed to me
at
(202) 551-3466, or in my absence to Bob Benton at (202) 551-3804.

								Sincerely,

								Matthew Maulbeck
								Staff Accountant

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Healthcare Realty Trust, Inc.
August 16, 2005

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