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CORRESP
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CORRESP

355 South Grand Avenue

Los Angeles, California 90071-1560

Tel: +1.213.485.1234 Fax: +1.213.891.8763

www.lw.com

FIRM / AFFILIATE OFFICES

Abu Dhabi

Moscow

Barcelona

Munich

Beijing

New Jersey

Boston

New York

Brussels

Orange County

April 22, 2026

Chicago

Paris

Doha

Riyadh

Dubai

Rome

Frankfurt

San Diego

Hamburg

San Francisco

Hong Kong

Shanghai

Houston

Silicon Valley

London

Singapore

Los Angeles

Tokyo

Madrid

Washington, D.C.

Milan

 VIA EDGAR

 Ameen
Hamady

 Shannon Menjivar

 Securities and Exchange Commission

 Division of Corporation Finance

 Office of Real
Estate & Construction

 100 F Street, N.E.

Washington, D.C. 20549

Re:
 Sunstone Hotel Investors, Inc.

Form 10-K for the Fiscal Year Ended December 31, 2025

Filed on February 27, 2026

Sunstone Hotel Investors, Inc.

Form 8-K

Filed on February 27, 2026

File No. 001-32319

Dear Ameen Hamady and Shannon Menjivar,

 On
behalf of Sunstone Hotel Investors, Inc. (the “Company”), this letter sets forth the Company’s response to the comments of the Staff of the Division of Corporation Finance (the “Staff”) of
the Securities and Exchange Commission (the “Commission”), dated April 13, 2026, with respect to the Company’s Annual Report on Form 10-K for the year ended
December 31, 2025 and Current Report on Form 8-K filed on February 27, 2026 (the “Form 8-K”). For your convenience, the Staff’s
comments are set forth below in italics, followed by the Company’s responses.

 Comment

Form 8-K: Exhibit 99.1 Unaudited Selected and Financial Data, page 2

1.
 We note your presentation of Adjusted FFO Attributable to Common Stockholders per Diluted share here and
as part of your 2026 Outlook. In future periodic filings, please present with equal or greater prominence the most directly comparable measure calculated in accordance with GAAP for this non-GAAP financial
measure. Refer to Item 10(e)(1)(i)(A) of Regulation S-K and Question 102.10(a) of the Division’s Corporation Finance Interpretations on Non-GAAP Financial
Measures.

 April 22, 2026

 Page
 2

 Response

The Company respectfully informs the Staff that in applicable future filings, it will revise its disclosures to present with equal or greater
prominence Net Income (Loss) Attributable to Common Stockholders per Diluted Share, which is the most directly comparable measure calculated in accordance with GAAP. Set forth in Exhibit A hereto is a copy of the earnings release that was included
as an exhibit to the Form 8-K, which has been marked to show the Company’s proposed revisions in response to the Staff’s comment (additions appear in bold underline and deletions in strikethrough font).

*   *   *   *   *

If you have any questions or comments with regard to these responses or other matters, or would like any additional information, please call
the undersigned at (213) 891-7421.

Sincerely,

/s/ Steven B. Stokdyk

 Steven B. Stokdyk

 of LATHAM & WATKINS
LLP

cc:
 Aaron R. Reyes, Executive Vice President & Chief Financial Officer, Sunstone Hotel Investors, Inc.

 Brent T. Epstein, Latham & Watkins LLP

 April 22, 2026

 Page
 3

 EXHIBIT A

[Redline of earnings release attached]

 Exhibit 99.1

 For Additional Information:

Aaron Reyes

 Sunstone Hotel Investors, Inc.

(949) 382-3018

SUNSTONE HOTEL INVESTORS REPORTS RESULTS FOR FOURTH QUARTER AND FULL YEAR 2025

Returned Over $170 Million to Common Stockholders in 2025 Through Dividends and Share Repurchases

Restores $500 Million Repurchase Authorization

ALISO VIEJO, CA – February 27, 2026 – Sunstone Hotel Investors, Inc. (the “Company” or “Sunstone”) (NYSE: SHO) today
announced results for the fourth quarter and full year ended December 31, 2025.

 Fourth Quarter 2025 Operational Results (as compared to Fourth
Quarter 2024):

•

 Net Income: Net income
attributable to common stockholders was
$3.27.2 million, or $0.02 per
diluted share, as compared to a net loss of $3.10.8 million, or a loss of $0.02 per diluted share.

•

 Total Portfolio RevPAR: Total Portfolio RevPAR increased 9.6% to $220.12. The average daily rate was
$319.01 and occupancy was 69.0%.

•

 Adjusted EBITDAre: Adjusted EBITDAre increased 17.6% to $56.6 million.

•

 Adjusted FFO: Adjusted FFO attributable to common stockholders per diluted share increased 25.0% to $0.20.

 Full Year 2025 Operational Results (as compared to Full Year 2024):

•

 Net Income: Net income
attributable to common stockholders was
$24.68.5 million, or $0.04 per diluted share, as compared to
$43.328.0 million, or $0.14 per
diluted share. Excluding the loss on the sale of the Hilton New Orleans St. Charles in June 2025, net income attributable to common stockholders for
the full year 2025 would have been
$33.317.2 million, or $0.09 per
diluted share.

•

 Total Portfolio RevPAR: Total Portfolio RevPAR increased 3.8% to $225.12. The average daily rate was
$317.07 and occupancy was 71.0%.

•

 Adjusted EBITDAre: Adjusted EBITDAre increased 3.0% to $236.6 million.

•

 Adjusted FFO: Adjusted FFO attributable to common stockholders per diluted share increased 7.5% to $0.86.

 Information regarding the non-GAAP financial measures disclosed in this release is provided
below in “Non-GAAP Financial Measures.” Reconciliations of non-GAAP financial measures to the most comparable GAAP measure for each of the periods presented
are included later in this release.

 Bryan A. Giglia, Chief Executive Officer, stated, “Our portfolio outperformed our expectations in the fourth
quarter delivering impressive Total RevPAR growth of 12.5% as the benefit of our recent investment activity added to generally broad-based strength across our portfolio. We were particularly encouraged by stronger performance at Andaz Miami Beach
and Wailea Beach Resort which saw robust demand over the festive period with the momentum continuing into 2026.”

 Mr. Giglia continued,
“While macroeconomic uncertainty and other factors impeded industry growth in 2025, we nevertheless had a productive year at Sunstone. We recycled out of a lower growth hotel and used the proceeds to accretively repurchase our stock, debuted
Andaz Miami Beach, completed other capital investments intended to drive future growth, and returned over $170 million to our shareholders through share repurchases and dividends. While we see reasons to be optimistic about the year ahead, we
remain cautious and know the operating environment can be impacted, both positively and negatively, by events outside of our control. In 2026, we will continue to execute our strategy of recycling capital, investing in our portfolio, and returning
capital to shareholders while working to address the valuation discount at which we trade. We have an exceptional portfolio with meaningful growth potential, a flexible balance sheet with optionality, a nimble size that allows us to pivot among the
most accretive capital allocation opportunities, and a singular focus to realize the embedded value of our portfolio for our shareholders.”

 1

 Unaudited Selected Statistical and Financial Data ($ in millions, except RevPAR, ADR and per share
amounts).

Quarter Ended December 31,

Year Ended December 31,

2025

2024

Change

2025

2024

Change

 Net Income

$
 7.2

$
 0.8

763.3
%

$
 24.6

$
 43.3

(43.2
)%

 Net Income (Loss)
Attributable to Common Stockholders

$
3.2

$
(3.1
)

204.4
%

$
8.5

$
28.0

(69.8
)%

 Net
Income (Loss) Attributable to Common Stockholders per Diluted Share

$
 0.02

$
(0.02
)

200.0
%

$
 0.04

$
 0.14

(71.4
)%

 Total Portfolio Operating Statistics (1)

 RevPAR

$
 220.12

$
 200.75

9.6
%

$
 225.12

$
 216.86

3.8
%

 Occupancy

69.0
%

65.1
%

390
bps

71.0
%

68.7
%

230
bps

 Average Daily Rate

$
 319.01

$
 308.37

3.5
%

$
 317.07

$
 315.66

0.4
%

 Total Portfolio Operating Statistics, excluding Andaz Miami Beach (2)

 RevPAR

$
 218.07

$
 209.38

4.2
%

$
 229.94

$
 225.31

2.1
%

 Occupancy

69.1
%

67.9
%

120
bps

72.7
%

71.3
%

140
bps

 Average Daily Rate

$
 315.59

$
 308.37

2.3
%

$
 316.28

$
 316.00

0.1
%

 Total Portfolio Hotel Adjusted EBITDAre Margin, excluding Andaz Miami Beach (2)

25.5
%

23.3
%

220
bps

26.7
%

26.3
%

40
bps

 Adjusted EBITDAre

$
 56.6

$
 48.1

17.6
%

$
 236.6

$
 229.7

3.0
%

 Adjusted FFO Attributable to Common Stockholders

$
 38.9

$
 32.0

21.4
%

$
 167.8

$
 163.0

3.0
%

 Adjusted FFO Attributable to Common Stockholders per Diluted Share

$
 0.20

$
 0.16

25.0
%

$
 0.86

$
 0.80

7.5
%

(1)
 Includes the 14 hotels owned by the Company as of December 31, 2025, and includes prior ownership results
for the Hyatt Regency San Antonio Riverwalk, acquired by the Company in April 2024.

(2)
 Includes the 14 hotels owned by the Company as of December 31, 2025, with the exception of Andaz Miami
Beach due to its renovation activity during 2025 and 2024. Includes prior ownership results for the Hyatt Regency San Antonio Riverwalk, acquired by the Company in April 2024.

The Company’s actual results for 2025 compare to its guidance previously provided as follows:

 Metric ($ in millions, except per share data)

Full Year 2025
Guidance (1)

Full Year 2025
Actual Results

Performance
Relative to Prior
Guidance Midpoint

 Net Income

$14 to $28

$25

+ $4

 Total Portfolio RevPAR Growth (2)

3.0% to 5.0%

3.8%

- 20 bps

 Total Portfolio RevPAR Growth, excluding Andaz Miami Beach (2)

1.0% to 3.0%

2.1%

+ 10 bps

 Adjusted EBITDAre

$226 to $240

$237

+ $4

 Adjusted FFO Attributable to Common Stockholders

$156 to $170

$168

+ $5

 Adjusted FFO Attributable to Common Stockholders per Diluted Share

$0.80 to $0.87

$0.86

+ $0.02

 Diluted Weighted Average Shares Outstanding

195,000,000

194,452,000

- 548,000

(1)
 Reflects guidance presented on November 7, 2025.

(2)
 RevPAR Growth reflects comparison to full year 2024.

2025 Highlights

 Andaz Miami Beach. In May 2025,
the Company opened Andaz Miami Beach, following a complete transformation of the property. The fully renovated luxury resort had a strong finish in 2025 and is expected to generate meaningful earnings growth for the Company in 2026 during its first
full year of operations. Later this year, the resort will introduce Olazul, a members only beach club and will also debut Bazaar Meat, a signature dining destination by José Andrés Group. In addition to substantial earnings growth in
2026, the Company expects Andaz Miami Beach will contribute further to earnings in 2027 and 2028 as it ramps up and stabilizes.

 2

 Hilton New Orleans St. Charles Disposition. In June 2025, the Company sold the 252-room Hilton New Orleans St. Charles for a gross sale price of $47.0 million. The sale price represented an 8.7% cap rate on the hotel’s prior year earnings or a 6.6% cap rate inclusive of the
Company’s estimate of near-term capital expenditures. The Company utilized proceeds received from the sale to accretively repurchase shares of its common stock.

Stock Repurchase Program. During 2025, the Company repurchased an aggregate amount of $103.6 million, before expenses, of its common and preferred
stock. In addition, from the start of this year through February 26, 2026, the Company has allocated an additional $7.5 million, before expenses, into repurchases of its common and preferred stock. The Company believes this repurchase
activity has been done on a discounted basis and generated significant value for its shareholders.

•

 Common stock: During 2025, the Company repurchased 11,589,722 shares at an average purchase price per
share of $8.83 for a total repurchase amount before expenses of $102.4 million. From the start of this year through February 26, 2026, the Company has repurchased 639,355 shares at an average purchase price per share of $8.88 for a total
repurchase amount before expenses of $5.7 million. Since the beginning of 2022, the Company has deployed approximately $300 million and repurchased 31.2 million shares of its common stock, representing over 14% of shares outstanding
at the start of the period, at an average purchase price of $9.60 per share. The average purchase price per share represents a substantial discount to consensus estimates of net asset value and implies a highly attractive valuation multiple on the
Company’s stabilized cash flow.

•

 Series H Cumulative Redeemable Preferred Stock: During 2025, the Company repurchased 54,097 shares at an
average purchase price per share of $20.28 for a total repurchase amount before expenses of $1.1 million. From the start of this year through February 26, 2026, the Company has repurchased 90,459 shares at an average purchase price per
share of $20.69 for a total repurchase amount before expenses of $1.9 million. The 2025 and 2026 average repurchase price of $20.54 per share reflects an 18% discount to the preferred stock liquidation value.

•

 Series I Cumulative Redeemable Preferred Stock: During 2025, the Company repurchased 9,027 shares at an
average purchase price per share of $19.25 for a total repurchase amount before expenses of $0.2 million. The average repurchase price per share reflects a 23.0% discount to the preferred stock liquidation value.

Amended and Restated Credit Agreement. In September 2025, the Company completed its Third Amended and Restated Credit Agreement (the “Amended
Credit Agreement”), which provides for an aggregate borrowing capacity of $1.35 billion, and allowed the Company to address all near term maturities, extend the duration of the remaining in-place
loans, and further strengthen the Company’s balance sheet. Inclusive of extension options, loans under the Amended Credit Agreement mature at various points in 2030 and 2031 but are freely prepayable at any time. In connection with the new
facilities, the Company entered into a series of interest rate swaps to lower its borrowing cost and better manage interest rate risk.

 Recent
Developments

 Stock Repurchase Program Reauthorization. In February 2026, Sunstone’s Board of Directors reauthorized the Company’s
stock repurchase program which allows the Company to acquire up to $500.0 million of its common and preferred stock. The authorization has no stated expiration and future repurchases under the program will depend on various factors including
the Company’s capital needs, other capital allocation opportunities available to the Company, and the price of the Company’s common and preferred stock. Including repurchase activity completed subsequent to the reauthorization, the
Company currently has nearly $500.0 million remaining under the new authorization.

 Delayed-Draw and Series A Senior Notes Repayment. In
January 2026, the Company drew the remaining $90.0 million available under its $275.0 million delayed-draw term loan facility and used a majority of the proceeds received to repay the $65.0 million balance of the Series A Senior Notes
at their scheduled maturity. Following this repayment, the Company has no debt maturities until 2028.

 Corporate Responsibility Report. In February
2026, the Company published its 2025 Corporate Responsibility Report. The report includes details on Sunstone’s progress related to its environmental sustainability, social responsibility and corporate governance initiatives during 2024, as
well as details of the Company’s performance towards its 2035 environmental targets. A copy of the report can be found on the Corporate Responsibility page of the Company’s website at www.sunstonehotels.com.

Balance Sheet and Liquidity Update

 As of
December 31, 2025, the Company had $185.7 million of cash and cash equivalents, including restricted cash of $76.5 million, total assets of $3.0 billion, including $2.8 billion of net investments in hotel properties, total
debt of $930.0 million and stockholders’ equity of $1.9 billion.

 3

 Capital Investments Update

The Company invested $29.4 million and $103.0 million into its portfolio during the fourth quarter and year ended December 31, 2025,
respectively. The majority