SecProbe.io

July 8, 2015

Mr. M ark T. Lammas
Chief Financial Officer
Hudson Pacific Properties, Inc.
11601 Wilshire Blvd., Sixth Floor
Los Angeles, CA 90025

Re: Hudson Pacific Properties, Inc.
 Form 10-K for the fiscal year ended December 31, 2014
Filed March 2, 2015
File No. 1-34789

Dear Mr. Lammas:

We have reviewed your filing an d have the following comments.  In some of our
comments, we may ask you to provide us with information so we may better understand your
disclosure.

Please respond to these comments  within ten busine ss days by providing the requested
information or advis e us as soon as possible when you will respond.  If you  do not believe our
comments apply to your facts and circumstances , please tell us why in your response.

After reviewing your response to these  comments, we may have additional comments.

Form 10 -K for the year ended December 31, 2014

Item 2.  Properties

Note (5), page 38

1. We note that you acquired the 12655 Jefferson property in October 2014 and it appears
that the tenant vacated the property at some point after the acquisition.  Please explain
how you determined it is appropriate to capitali ze rent received from the vacated tenant.
In your explanation, please provide the relevant facts concerning the lease termination
agreement and cite the relevant accounting literature you relied upon.

Item 7. Management’s Discussion and Analysis of Finan cial Condition and Results of
Operations, page 52

2. We note you disclosed FFO, FFO (excluding specified items) and adjusted FFO  in your
earnings release and supplemental package as key performance measures.   In future

Mr. Mark T. Lammas
Hudson Pacific Properties, Inc.
July 8 , 2015
Page 2

 filings please include these measures a s well as the required disclosure in accordance
with Item 10(e) of Regulation S -K within your Management’s Discussion and Analysis.

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 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 acc uracy
and adequacy of the disclosures they have made.

 In responding to our comments, 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 Commissi on or any person under the federal securities laws of the United States.

You may contact Peter McPhun, Staff  Accountant at 202-551-3581 or the undersigned  at
202-551-3486 if you have questions .

Sincerely,

 /s/ Daniel L. Gordon

 Daniel L. Gordon
Senior Assistant Chief Accountant