SecProbe.io

April 17, 2013

Via Email
Mr. Bryan A. Giglia
Chief Financial Officer
Sunstone Hotel Investors, Inc.
120 Vantis, Suite 350
Aliso Viejo, CA  92656

Re: Sunstone Hotel Investors, Inc.
 Form 10-K
Filed February  25, 2013
File No. 001 -32319

Dear Mr. Giglia :

We have reviewed your filing an d have the following comment.  In 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 advising us when you will provide the requested
response.   If you do not believe our comment applies  to your facts and circumstanc es or do not
believe an amendment is appropriate, please 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.

Item 7. Manag ement’s Discussion and Analysis of Financial Condition and Results of
Operations, page 30

Non-GAAP Financial Measures, page 37

1. Please include a statement as to why management believes the presentation of Adjusted
EBITDA provides useful information to inv estors regarding your financial position or
results of operations in accordance with Item 10(e)(1)(i)(C).  In that regard, we note your
disclosure on pages 37 – 38 regarding the usefulness of EBITDA and Adjusted EBITDA,
but you disclosure appears to addres s only EBITDA.  Please revise to describe
specifically why the further adjustments made to EBITDA result in a measure that is also
useful to investors.  This comment is applicable to Adjusted FFO as well.  Please provide
us with your proposed revisions.

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 the information the Securities Exchange Act of

Bryan A. Giglia
Sunstone Hotel Investors, Inc.
April 17, 2013
Page 2

 1934 and all applicable Exchange Act rules require.   Since the compan y 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 comments, please provide  a written statement from the com pany
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 t o 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 federal securities laws of the United States.

You may contact Kristi Marrone at (202) 551 -3429 me  at (202) 551-3694  if you have
questions regarding comments on the financial statements and r elated matters.

Sincerely,

 /s/ Jonathan Wiggins

Jonathan Wiggins
Staff Accountant