SecProbe.io

March 20, 2012
 Larry K. Harvey Executive Vice President, Chief Financial Officer Host Hotels & Resorts, Inc. 6903 Rockledge Drive, Suite 1500 Bethesda, Maryland 20817
Re: Host Hotels & Resorts, Inc.
 Form 10-K
Filed February 22, 2012 File No. 001-14625  Host Hotels & Resorts, L.P. Form 10-K Filed February 22, 2012 File No. 333-55807

Dear Mr. Harvey:
 We have reviewed your filing and 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 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 comments apply 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 these comments, we ma y have additional comments.

Larry K. Harvey Host Hotels & Resorts, Inc. March 20, 2012 Page 2

 Form 10-K for the year ended December 31, 2011

 Item 7. Management’s Discussion and Analys is of Financial Condition and Results of
Operations
 Summary of 2011 Operating Results, page 46

1. Please provide us with more information rega rding the properties you have classified as
comparable hotels.  In your response, explain to us what you consider to be a large scale
capital improvement, clarify for us when  these properties are removed from the
comparable hotels and when they are subseque ntly reclassified as comparable hotels.
Given the major capital projects that were  on-going at the Sheraton New York Hotel &
Towers and the Philadelphia Marriott Downto wn, explain to us why you have continued
to classify these properties as comparable hotels.
 Hotel Sales Overview, page 52

2. Please explain to us whether you considered  the renovation of the Miami Biscayne Bay
Marriott to be a large scale capital improve ment.  In your respons e tell us whether the
property was considered to be a comparab le hotel prior to the completion of the
renovation, tell us the date that renovations were completed, a nd explain to us the impact
that the ongoing renovation had on op erations prior to completion.
 Comparable Hotel Operating Statistics, page 80

3. We note that you have classified 104 of your  121 hotels as comparab le hotels as of
December 31, 2011.  Please clarify for us which of your 17 hotels were considered to be
non-comparable as of year end.  In your re sponse, tell us on a pr operty by property basis
why each hotel was not considered to be comp arable.  Additionally, explain to us any
changes in hotels considered to be compar able from the December 31, 2010 to December
31, 2011.  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.

Larry K. Harvey Host Hotels & Resorts, Inc. March 20, 2012 Page 3

  In responding to our comments, please provi de 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.

You may contact Robert Telewicz, Staff A ccountant at (202)551-3438 or the undersigned
at (202)551-3629 if you have questions.
Sincerely,
   /s/ Kevin Woody
Kevin Woody Accounting Branch Chief