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SEC Company Response from Piedmont Realty Trust, Inc. (PDM) (CIK 0001042776) (PDM) — Feb 5, 2010

Piedmont Realty Trust, Inc. (PDM) (CIK 0001042776)
Date: Feb. 5, 2010 · CIK: 0001042776 · Accession: 0001193125-10-023087

AI Filing Summary & Sentiment

File numbers found in text: 333-163394

Date
February 5, 2010
Author
/s/ Laura P. Moon
Form
CORRESP
Company
Piedmont Realty Trust, Inc. (PDM) (CIK 0001042776)

Letter

Securities and Exchange Commission Division of Corporation Finance Washington, D.C. 20549 RE: Piedmont Office Realty Trust, Inc. Registration Statement on Form S-11 File No.: 333-163394

Dear Ms. McHale:

Pursuant to Rule 461 promulgated under the Securities Act of 1933, as amended, Piedmont Office Realty Trust, Inc. (the “Registrant”) hereby requests acceleration of the effective date of its Registration Statement on Form S-11 (File No. 333-163394) (the “Registration Statement”) to 2:00 p.m., Washington, D.C. time, on Tuesday, February 9, 2010, or as soon thereafter as practicable.

In addition, the Registrant hereby acknowledges the following:

•

should the Securities and Exchange Commission (“Commission”) or the staff, acting pursuant to delegated authority, declare the Registration Statement effective, it does not foreclose the Commission from taking any action with respect to the Registration Statement;

•

the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the Registration Statement effective, does not relieve the Registrant from its full responsibility for the adequacy and accuracy of the disclosure in the Registration Statement; and

•

the Registrant may not assert this action as a defense in any proceeding initiated by the Commission or any other party under the federal securities laws of the United States.

* * *

Piedmont Office Realty Trust, Inc.

February 5, 2010

Page 2

Please contact the undersigned at (770) 418-8800 with any questions concerning this letter.

Sincerely,
/s/ Laura P. Moon

Show Raw Text
CORRESP
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filename1.htm

Correspondence

 February 5, 2010

 VIA FACSIMILE AND EDGAR

 Ms. Angela McHale

 Securities and Exchange Commission

 Division of
Corporation Finance

 100 F Street, N.E.

 Washington, D.C. 20549

RE:
Piedmont Office Realty Trust, Inc.

 Registration Statement on Form S-11

 File No.: 333-163394

 Dear Ms. McHale:

 Pursuant to Rule 461 promulgated under the Securities Act of 1933, as amended, Piedmont Office Realty Trust, Inc. (the “Registrant”) hereby requests acceleration of the effective date of its Registration Statement on Form S-11
(File No. 333-163394) (the “Registration Statement”) to 2:00 p.m., Washington, D.C. time, on Tuesday, February 9, 2010, or as soon thereafter as practicable.

 In addition, the Registrant hereby acknowledges the following:

•

 should the Securities and Exchange Commission (“Commission”) or the staff, acting pursuant to delegated authority, declare the Registration
Statement effective, it does not foreclose the Commission from taking any action with respect to the Registration Statement;

•

 the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the Registration Statement effective, does not relieve
the Registrant from its full responsibility for the adequacy and accuracy of the disclosure in the Registration Statement; and

•

 the Registrant may not assert this action as a defense in any proceeding initiated by the Commission or any other party under the federal securities
laws of the United States.

 * * *

 Piedmont Office Realty Trust, Inc.

 February 5, 2010

 Page 2

 Please contact the undersigned at (770) 418-8800 with any questions concerning this letter.

Sincerely,

/s/ Laura P. Moon

Laura P. Moon

 Senior Vice President and

 Chief Accounting Officer

cc:
Mr. John J. Kelley III — King & Spalding LLP