SecProbe.io

June 18, 2010

Victor J. Coleman Chief Executive Officer Hudson Pacific Properties, Inc. 11601 Wilshire Blvd., Suite 1600
Los Angeles, California 90025

Re:  Hudson Pacific Properties, Inc.
Amendment No. 6 to Registrati on Statement on Form S-11
Filed June 17, 2010
  File No. 333-164916

Dear Mr. Coleman:

We have reviewed your registration statem ent and have the following comments.  In
some of our comments, we may ask you to provi de us with information so we may better
understand your disclosure.
 Please respond to this letter by amending your registration statement and providing the
requested information.  If you do not believe  our comments apply to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
 After reviewing any amendment to your re gistration statement and the information you
provide in response to these comments, we may have additional comments.

Our Properties, page 7
1. We note your response to comment 3 of our letter dated June 16, 2010.  Please revise
your disclosure preceding the tables on pages 7 and 97 to include a sentence clarifying
that the data presented in the table is ba sed on the leases in place as of March 31, 2010
and does not reflect historical  rental amounts except with  respect to the media and
entertainment properties.  With respect to th e media and entertainment properties, please
clarify, if true, that the annual rent for these properties reflects actual rent for the 12 months ended March 31, 2010 because these pr operties are not subject to long-term
leases and that all leases for these properti es expire in 2010 or 2011.  In addition, please
revise the heading of the last  column to state, as it had previously, “Annualized Net
Effective Rent Per Leased Square Foot” or otherwise explain how your change clarifies
the calculation.

Victor J. Coleman
Hudson Pacific Properties, Inc.
June 18, 2010 Page 2

2. We note footnotes (3) and (5) on pages 8 and 98.  Please revise the data in the tables on
pages 7 and 97 to reflect scheduled lease expirations and present such data without converting to gross by adding expense reimbursements to base rent or otherwise grossing-up leases.  Please revise to make  similar disclosures throughout your prospectus,
including footnote (8) on page 8 and the Bu siness and Properties section beginning on
page 92.  To the extent you continue to refe r to “non-gross leases,”  please briefly explain
what you mean by the term.
3. We note footnote (8) on pages 8 and 98.  Please revise the tabl e within this footnote to
reflect to actual annualized rent under the uncommenced leases net of abatements and, as appropriate, reflect the annualiz ed rent without accounting for such abatements in a
footnote to such table.
Description of Our Media and En tertainment Properties, page 115

4. Refer to footnotes (2) and (3) to the tables  on pages 116 and 119 that reflect percentage
leased, annual rent per square  foot and annual net effective rent per lease square foot.
The footnotes indicate that the information presented in the percent leased and annual rent per leased square foot columns is as of a three or 12-month period.  However, the information presented on pages 116 and 119 as  of the three-month period ended March
31, 2010 appears to correspond to the informati on presented as of the 12-month period
ended March 31, 2010 on pages 7 and 97.  Please revise or advise.

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 incl udes the information the Securities Act of 1933 and
all applicable Securities Act rules require.  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.                Notwithstanding our comments, in the event you request accelera tion of the effective date
of the pending registration statement please pr ovide a written statement from the company
acknowledging that:
ƒ should the Commission or the staff, acting purs uant to delegated authority, declare the
filing effective, it does not foreclose the Co mmission from taking any action with respect
to the filing;

ƒ the action of the Commission or the staff, acting pursuant to delegated authority, in
declaring the filing effective, does not relieve the company from its full responsibility for
the adequacy and accuracy of the disclosure in the filing; and

Victor J. Coleman
Hudson Pacific Properties, Inc. June 18, 2010 Page 3

ƒ the company may not assert staff comments a nd the declaration of effectiveness as a
defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

Please refer to Rules 460 and 461 regarding re quests for acceleration.  We will consider a
written request for acceleration of  the effective date of the regi stration statement as confirmation
of the fact that those reques ting acceleration are aware of thei r respective responsibilities under
the Securities Act of 1933 and the Securities Excha nge Act of 1934 as they relate to the proposed
public offering of the securities specified in the above registration stat ement.  Please allow
adequate time for us to review any amendment prior to the requested effective date of the registration statement.
You may contact Yolanda Cr ittendon, Staff Accountant, at (202) 551-3472, or Cicely
LaMothe, Accounting Branch Chief, at ( 202) 551-3413, if you have questions regarding
comments on the financial statements and related ma tters.  With respect to questions relating to
our comment regarding the Invest ment Company Act, please contact Rochelle Plesset in the
Division of Investment Manageme nt at (202) 551-6840.  Please c ontact Erin Martin, Attorney-
Advisor, at (202) 551-3391 or me at (202) 551-3401 with any other questions.

     S i n c e r e l y ,

Jennifer Gowetski Senior Counsel
 cc: Julian T.H. Kleindorfer, Esq.      Bradley A. Helms, Esq.      Latham & Watkins, LLP
     Via facsimile (213) 891-8763