SecProbe.io

Mailstop 3233
April  19, 201 7

Via E-mail
Mr. Gregory J. Larson
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.
Host Hotels & Resorts, L.P.
 Form 10-K for the  fiscal  year e nded December 31, 201 6
Filed February  24, 201 7
File No. 001 -14625 (Host Inc.)
File No. 333 -55807 (Host L.P.)

Dear Mr. Larson :

We have limited our review of your filing s to the financial statements and related
disclosures 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 these comments within ten business days by providing the requested
information or advise us as soon as p ossible when you will respond.  If you do not believe our
comments apply to your facts and circumstances, please tell us why in your response.

After reviewing your response to these comments, we may have additional comments.

Mr. Gregory J. Larson
Host Hotels & Resorts, Inc.
Host Hotels & Resorts, L.P.
April  19, 201 7
Page 2

 Form 10 -K for the fiscal year ended December 31, 2016

Item 7. Management’s Discussion and Analysis of Financial Condition and Results of
Operations

Non-GAAP Financial Measures, page 75

1. We note your reconciliation of Comparable hotel EBITDA to Net income on page 81.  In
future filings please begin the  reconciliation with Net income, to give equal or greater
prominence to the GAAP measure being presented.  Please refer to Question 102.10 of
the C&DIs on Non -GAAP Financial Measures.  This comment is also applicable to the
extent this measure is presented  in your earnings release filed on Form 8 -K and within
the supplemental financial information posted on your website.

Item 8. Financial Statements and Supplementary Data

15. Geographic and Business Segment Information, page 128

2. We note your disclosure t hat all of your operating segments meet the aggregation criteria
to be grouped as a single reportable segment.  Please tell us how you considered the need
to aggregate your operating segments into reportable segments by brand or property type.
In your res ponse, please explain to us in sufficient detail how you determined all of your
operating segments meet the aggregation criteria of ASC Topic 280 -10-50-11.

We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.

You may contact Jeffrey Lewis, Staff Accountant, at (20 2) 551 -6216 or the undersigned
at (202) 551 -3438 with any questions.

Sincerely,

/s/ Robert F. Telewicz, Jr.

Robert F. Telewicz, Jr.
Accounting Branch Chief
Office of Real Estate and
Commodities