SecProbe.io

April 21, 2011
 Larry K. Harvey Chief Financial Officer Host Hotels & Resorts, Inc. Host Hotels & Resorts, L.P.
6903 Rockledge Drive
Suite 1500 Bethesda, MD 20817
Re: Host Hotels & Resorts, Inc.
Form 10-K for Fiscal Year Ended December 31, 2010 Filed February 24, 2011 File No. 001-14625   Host Hotels & Resorts, L.P. File No. 333-55807

Dear Mr. Harvey:
 We have reviewed your filing and have the following comment.  In our comment, we
may ask you to provide us with informati on 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 advi sing us when you will provide the requested
response.  If you do not believe our comment applies to your fact s and circumstances or do not
believe an amendment is appropriate, pl ease tell us why in your response.
 After reviewing any amendment to your filing and the information you provide in
response to this comment, we may have additional comments.

Larry K. Harvey
Host Hotels & Resorts, Inc. Host Hotels & Resorts, L.P.  April 21, 2011 Page 2

Form 10-K

 Financial Statements

 Notes to Consolidated Financial Statements

 18. Legal Proceedings, page 141

 1. We note the fourth paragraph in your legal pr oceedings footnote.  With respect to your
various other legal proceedings, we note that  you have not disclosed in your financial
statement footnotes: (i) the possible loss or range of loss; or
(ii) a statement that an estimate of the loss cannot be made
ASC 450 (formerly SFAS 5) indicates that if an  unfavorable outcome is determined to be
reasonably possible but not probable, or if  the amount of loss cannot be reasonably
estimated, accrual would be inappropriate, but  disclosure must be made regarding an
estimate of the possible loss or range of possible loss or state that such an estimate cannot
be made.  Please revise your disclosures be ginning in the first quarter Form 10-Q to
include all of the disclosures required by paragraphs 1 and 3- 5 of ASC 450-20-50.  In this
regard, we do not believe that general boilerp late disclosure indicat ing that the outcome
of a matter may be material to your operating results for a particular period satisfies the
criteria in ASC 450.  We urge all persons who are responsible for th e accuracy and adequacy of the disclosure
in the filing to be certain that the filing include s the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules requir e.  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 responding to our comment, please provide a written statement from the company
acknowledging that:
• the company is responsible for the adequacy an d accuracy of the disclo sure 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 federa l securities laws of  the United States.

Larry K. Harvey
Host Hotels & Resorts, Inc. Host Hotels & Resorts, L.P.  April 21, 2011 Page 3

You may contact Jennifer Moni ck, Senior Staff Accountan t, at 202-551-3295 or me at
202-551-3629 if you have questions.
Sincerely,

Kevin Woody Branch Chief