SecProbe.io

September 10 , 201 4

Via E -mail
Mr. Mark T. Lammas
Chief Financial Officer
Hudson Pacific Properties, Inc.
11601 Wilshire Blvd. , Sixth  Floor
Los Angele s, CA  90025

Re: Hudson Pacific Properties, Inc.
 Form 10-K for the  fiscal  year ended December  31, 2013
Filed March  3, 201 4
File No. 1-34789

Dear Mr. Lammas :

We have reviewed your filing an d have the following comment.   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.

Form 10 -K for the year ended December 31, 2013

General

1. We note  your response to comment 1 of our letter dated August 7, 2014 in which you
indicate that you consider FFO to be a meaningful metric for a REIT to assess its
operational performance in conjunction with other me trics.  In future Exchange Act
periodic reports, please include FFO disclosure. Also provide the appropriate GAAP
reconciliation and highlight any differences from the NAREIT definition.

We urge all 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 Exchange 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.

Mr. Mark Lammas
 Hudson Pacific Properties, Inc.
 September 10 , 201 4
 Page 2

             In responding to our comment, please 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 Commission 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 Howard Efron, Staff Accountant, at (202) 551-3439 or Jennifer Monick, Staff
Accountant  at (202) 551 -3295 if you have questions regarding comments on the financial
statements and related matters.  Please contact Sandra  Hunter , Staff Attorney, at (202) 551 -3758
or me at (202) 551 -3673 with regard to legal comments.

Sincerely,

        /s/ Folake Ayoola

Folake Ayoola
Senior Counsel