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 Document PIEDMONT OFFICE REALTY TRUST, INC VIA EDGAR AND EMAIL June 2, 2025 Ms. Mary Beth Breslin Industry Office Chief Division of Corporation Finance Office of Real Estate and Construction U.S. Securities and Exchange Commission 100 F Street, NE Washington D.C. 20549 Re: Piedmont Office Realty Trust, Inc. Form 10-K for the year ended December 31, 2024, Filed on February 19, 2025 File No. 001-34626 Dear Ms. Breslin: This letter is submitted in response to the comments by the staff of the Division of Corporation Finance (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”) with respect to the above referenced filing by Piedmont Office Realty Trust, Inc. (the “Company”). We welcome the opportunity to discuss our response with you, and I am available to do so at (770) 418-8603 or Sherry Rexroad, our Chief Financial Officer, is available at (770) 418-8604. For your convenience, we have repeated each comment by the Staff immediately preceding our response. Form 10-K for the year ended December 31, 2024 6. Impairment Charges, page F-23 Comment: 1. Please revise your disclosure to include the goodwill disclosures required by ASC 350-20-50-1 for each of your reportable segments as well as in total. Response: We will include in future filings, beginning with our quarterly report on Form 10-Q for the quarter ending June 30, 2025, the following goodwill disclosures required by ASC 350-20-50-1 for each of our reportable segments as well as in total. Presented below for illustrative purposes is a table with information for the years ended December 31, 2024, and 2023 to show an example of the enhanced disclosure approach we intend to take in our future filings: The change in the carrying amount of Piedmont’s goodwill allocated to each of its reportable segments and in total as of December 31, 2024 and 2023 is as follows (in thousands): Atlanta Dallas Orlando Northern Virginia/ Washington, D.C. Minneapolis New York Boston Total Balance as of January 1, 2023: Goodwill $ 18,563  $ 18,525  $ 10,818  $ 15,981  $ 10,957  $ 10,585  $ 13,489  $ 98,918   Accumulated impairment charges —  —  —  (15,981) —  —  —  (15,981) 18,563  18,525  10,818  —  10,957  10,585  13,489  82,937   2023 impairment charges —  —  —  —  (10,957) (5,000) (13,489) (29,446) Balance as of December 31, 2023: Goodwill 18,563  18,525  10,818  15,981  10,957  10,585  13,489  98,918   Accumulated impairment charges —  —  —  (15,981) (10,957) (5,000) (13,489) (45,427) 18,563  18,525  10,818  —  —  5,585  —  53,491   2024 impairment charges —  —  —  —  —  —  —  —   Balance as of December 31, 2024: Goodwill 18,563  18,525  10,818  15,981  10,957  10,585  13,489  98,918   Accumulated impairment charges —  —  —  (15,981) (10,957) (5,000) (13,489) (45,427) $ 18,563   $ 18,525   $ 10,818   $ —   $ —   $ 5,585   $ —   $ 53,491   Comment: 2. We note your disclosure that you recorded losses for impairment on real estate assets in 2024 and 2022. Please tell us and revise future filings to disclose the segment in which the impaired long-lived asset (asset group) is reported. Refer to ASC 360-10- 50-2(d). Response: Our recorded losses for impairment on real estate assets in 2024 and 2022 are related to the following segments: Building Reportable Segment 2024 2023 2022 One Lincoln Park Dallas $ 932   $ —  $ —  750 West John Carpenter Freeway Dallas 17,500   —  —  80 and 90 Central Street Boston 10,000   —  —  161 Corporate Center Dallas 5,400   —  —  9320 Excelsior Boulevard Minneapolis —   —  10,000  Total impairment charge on real estate assets $ 33,832   $ —  $ 10,000  We will include in future filings, beginning with our quarterly report on Form 10-Q for the quarter ending June 30, 2025, disclosure of the reportable segment in which the impaired long-lived asset is reported in accordance with ASC 360-10-50-2(d). May 28, 2025 Page 2 Sincerely, /s/ Laura P. Moon Laura P. Moon Chief Accounting Officer Piedmont Office Realty Trust, Inc.     CC:     Mr. C. Brent Smith, President, Principal Executive Officer and Director     Ms. Sherry L. Rexroad, Chief Financial Officer, Principal Financial Officer     Mr. Will Herman, Deloitte & Touche LLP     Mr. Keith Townsend, Esq., King & Spalding, LLP