SecProbe.io

Mail Stop 4561
April 1, 2009

Mr. Larry K. Harvey Chief Financial Officer Host Hotels & Resorts, Inc. 6903 Rockledge Drive, Suite 1500 Bethesda, Maryland  20817

Re: Host Hotels & Resorts, Inc.
Form 10-K for the year ended December 31, 2008
File No. 001-14625

Dear Mr. Harvey:

We have reviewed your filing and have the following comment.  We have limited
our review to only the issue addressed below and do not intend to expand our review to
other portions of your documents.  Where i ndicated, we think you should revise your
document in response to our comment.  If  you disagree with our comment, we will
consider your explanation as to why our comment is inapplicable or a revision is
unnecessary.  Please be as detaile d as necessary in your explan ation.  In our comment, we
may ask you to provide us with information so we may better understand your disclosure.
After reviewing this information, we may raise additional comments.

 Please understand that the purpose of our re view 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 any other aspect of our review.  Feel free to call us at the telephone numbers listed at the end of this letter.

Mr. Harvey
Host Hotels & Resorts, Inc.
April 1, 2009 Page
2
  Form 10-K for the year ended December 31, 2008

 Management’s Discussion and Analysis of Re sults of Operations and Financial Condition

 Critical Accounting Policies

 Impairment Testing, page 68

1. You have disclosed in your filing that the majo rity of your hotels are classified as
luxury or upper-scale hotels and that this segment of th e hotel industry appears to
be most vulnerable to a severe recessi on as consumers and commercial parties
look to save money.  You have further disclosed in your 2009 outlook on page 45
that you believe that the economic slow down will significantly affect both the
group and transient elements of your bus iness and that 2008 RevPar decreased
from the prior year across all of you r hotel property types with the most
significant decline of 17.1% at your Hawaiian properties.   Explain to us and
clarify in this filing how this severe  recession has impacted your impairment
analysis under SFAS 144 and the related assumptions used in determining future cash flows from your hotel properties.  Finally, please specifi cally address the
Hawaiian properties in your response as  these properties have experienced
significant declines in RevP ar and a couple of the Hawa iian properties were noted
to have been acquired as recently as 2003.

As appropriate, please respond to our comm ent within 10 business days or tell us
when you will provide us with a response.  Please submit a response letter on EDGAR that keys your response to our comment and provide any requested information.  Detailed
cover letters greatly facilitate  our review.  Please understand that we may have additional
comments after reviewing your  response to our comment.
  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 all in formation required under
the Securities Exchange Act of 1934 and th at they have provided all information
investors require for an informed decision.  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 the disclosures they have made.     In connection with responding to our comments, please provide, in writing, a 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

Mr. Harvey
Host Hotels & Resorts, Inc. April 1, 2009 Page
3

• 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.

In addition, please be advise d that the Division of Enfo rcement has access to all
information you provide to the staff of the Divi sion of Corporation Fi nance in our review
of your filing or in response to our comments on your filing.
 You may contact Howard Ef ron, Staff Accountant, at  (202) 551-3439 or me at
(202) 551-3629 if you have questions regard ing comments on the financial statements
and related matters.

         S i n c e r e l y ,
   Kevin Woody Branch Chief