SecProbe.io

April 10, 2012
                                                                                                  Via E-Mail

Donald A. Miller Chief Executive Officer Piedmont Office Realty Trust, Inc. 11695 Johns Creek Parkway, Suite 350 Johns Creek, GA  30097
                 Re: Piedmont Office Realty Trust, Inc.
Form 10-K for the Fiscal Year Ended December 31, 2011 Filed February 28, 2012 File No. 001-34626

Dear Mr. Miller:

We have reviewed your filing and have the following comments.  In some of our
comments, we may ask you to provide us w ith information so we may better understand
your disclosure.
 Please respond to this letter within ten business days by amending your filing, 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
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
 After reviewing any amendment to your filing and the information you provide in
response to these comments, we ma y have additional comments.

Form 10-K for the Fiscal Year Ended December 31, 2011 filed February 28, 2012

 Item 7. Management’s Discussion and Analys is of Financial Condition and Results of
Operations, page 29
 1. Please refer to your Form 8-K filed Fe bruary 10, 2012 that includes your press
release dated February 9,  2012.  We note your disclosure of Core net operating
income (“Core NOI”) and Same store net operating income (“Same Store NOI”).
We also note your disclosure that you be lieve Same Store NOI is an important
measure of comparison of your stabilized properties’ operating performance, and
you use Core NOI to assess your operating re sults and believe it is important in
assessing operating performance. Please include such perfor mance measures in

Donald A. Miller
Piedmont Office Realty Trust, Inc.
April 10, 2012 Page 2

 future Form 10-K filings with the appr opriate reconciliation required by Rule
10(e) of Regulation S-K.
 Note 13.    Commitments and Contingencies

 Assertion of Legal Action, page F-24

 2. We note your disclosure of the range of gross potential
 loss.  Since ASC 450 does
not use the term potential loss, please revise your disclosure in future filings to clarify that, as we assume, what  you mean is reasonably possible
 loss.  Refer to
ASC 450-20-50-4 and ASC 450-20-25-1.

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 Exch ange Act rules require.  Since the company
and its management are in possession of all f acts 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 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 comme nts as a defense in any proceeding
initiated by the Commission or any person under the federal secu rities laws of the
United States.
 If you have any questions, you may contact  Jorge L. Bonilla at (202) 551-3414 or
me at (202) 551-3486.

                                                                                     Sincerely,                                                                                                       /s/ Daniel L. Gordon
Daniel L. Gordon
                                                                                    Branch Chief