SecProbe.io

Mail Stop 3233
August 23, 2016

Via E -mail
Mr. Robert E. Bowers
Chief Financial Officer and Executive Vice President
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 year ended December 31, 2015
Filed on February 17, 2016
File No. 001 -34626

Dear Mr. Bowers :

We have reviewed your filing an d have the following comments.  In some  of our
comments, we may ask you to provide us with information so we may better understand your
disclosure.

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

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

Form 10 -K for the fiscal year ended December 31, 2015

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

Funds from Operations, Core Funds from Operations (Core FFO) and Adjusted Funds from
Operations (AFFO), page 36

1. Please tell us how Core FFO a nd AFFO are useful to an investor and how they should be
used by an investor.  It is not clear how you determined which adjustments should be
used to arrive at each measure.

2. In addition it appears that all of your adjustments to arrive at AFFO applicable to
common stock are non -cash adjustments.  This appears to be a liquidity measure and may

Mr. Robert E. Bowers
Piedmont Office Realty Trust, Inc.
August 23, 2016
Page 2

 be inconsistent with the updated Compliance and Disclosure Interpretations issued on
May 17, 2016 (specifically Questions 102.02 and 102.05).  Please review this guid ance
when preparing your next earnings release and periodic report.

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 t he 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 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 Shannon Sobotka, Staff Accountant at (202) 551 -3856,  or the
undersigned  at (202) 551 -3486  if you have questions regarding comments on the financial
statements and related matters.  Please cont act Nicole Collings, Staff Attorney at (202) 551 -6431
or Jennifer Gowetski, Senior Counsel  at (202) 551 -3401 with any other questions.

Sincerely,

 /s/ Daniel L. Gordon

Daniel L. Gordon
Senior Assistant Chief Accountant
Office of Real Estate and
Commodities