SecProbe.io

June 25 , 2013

Via U.S. M ail
Mr. Mark T . Lammas
Chief Financial Officer
Hudson Pacific Properties , Inc.
11601 Wilshire Blvd .
Suite 1600
Los Angeles, CA 90025

Re: Hudson Pacific Properties , Inc.
 Form 10-K for year ended December 31, 201 2
Filed on March 14, 2013
File No. 001-34789

Dear Mr. Lammas :

We have reviewed your filing an d have the following comments.  We have limited our
review to only your financial statements and related disclosures and do not intend to expand our
review to other portions of your document.  In some of our comments, we may ask you to
provide us with information so we may better underst and 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 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 filing and the information you provide in
response to these  comments, we may have  additional comments.

Form 10 -K for the year ended December 31, 2012

Item 7. Management’s Discussion and Analysis of Financial Condition and Results of
Operations, page 36

General

1. You disclose same store NOI in your Supplemental Operating and Financial Data  exhibit
to your Form 8 -K filed March 6, 2013.  Please tell us if you consider same store NOI to
be key operating performance measure.  To the extent you believe it is a key opera ting
performance measure, in future periodic filings, please disclose this measure wi thin your
MD&A and discuss any period over period changes in this measure.  Further, your
disclosure should clearly define how you determined the same store pool.

Mr. Mark T. Lammas
Hudson Pacific Properties, Inc.
 June 25 , 2013
 Page 2

 Factors That May Influence Our Operating Results, page 38

Rental Revenue, page 39

2. In future  periodic filings, please disclose if any office leases that you renewed during the
period were renewed at, below, or above the prior rent.

Critical Accounting Policies, page 40

Investment in Real Estate Properties, page 40

3. It appears that you capitalize d certain internal costs to your Investment in Real Estate
Properties.  In future filings, to the extent material, please quantify and disclose personnel
costs capitalized for all periods presented and discuss fluctuations in ca pitalized
personnel costs for all periods presented within your MD&A.

Results of Operations, page 42

Comparison of the year ended December 31, 2012 to the year ended December 31, 2011, page
42

4. We note you have multiple factors that impact your results o f operations for several line
items.  For example, we note that Media & Entertainment Rental Revenue increased due
to higher rents and occupancy.  In future filings, please separately quantify the impact
from each factor.

Financial Statements

Consolid ated Statements of Operations, page F -5

5. Please tell us how you determined it was appropriate to present Dividend declared per
common share on the face of the income statement.  Please refer to paragraph 5 of ASC
260-10-45.

Notes to Consolidated Financi al Statements, page F -10

2. Summary of Significant Accounting Policies, page F -10

Revenue Recognition, page F -12

6. On page 27, you disclose that GSA and Saatchi &  Saatchi North America, Inc. may
terminate their lease prior to expiration.  Please tell us how you considered this
termination option in your calculation of rental revenue on a straight -line basis.  Please
refer to ASC 840 -20.

Mr. Mark T. Lammas
Hudson Pacific Properties, Inc.
 June 25 , 2013
 Page 3

 10. Equity, page F -22

Stock-Based Compensation, page F -25

Hudson Pacific Properties, Inc. 2012 Outperformance Program, page F -26

7. Please tell us how you complied with ASC 718 -10-50, or tell us how you determined it
was not necessary to disclose the method of estimating the fair va lue of the 2012
Outperformance Program.

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
1934 and all applicable Exc hange 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.

 In responding to our comments, pleas e provide  a written statement from the company
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 Commis sion 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 federal securities laws of the United States.

You may contact Jennifer Monick, Senior Staff Accountant, at 202 -551-3295  or the
undersigned at 202-551-3629 if you have questions.

Sincerely,

 /s/ Kevin Woody

Kevin Woody
Branch Chief