SEC Company Response from Hudson Pacific Properties, Inc. (HPP, HPP-PC) (CIK 0001482512) (HPP) — Jul 15, 2011
Hudson Pacific Properties, Inc. (HPP, HPP-PC) (CIK 0001482512)
Date: July 15, 2011 · CIK: 0001482512 · Accession: 0001193125-11-189498
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-175326
Letter
Correspondence Letter
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
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July 15, 2011
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VIA EDGAR AND OVERNIGHT COURIER
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Securities and Exchange Commission
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Division of Corporate Finance
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Mail Stop 4631
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100 F Street, N.E.
Madrid
Washington, D.C.
Washington, D.C. 20549
Milan
Attention:
Tom Kluck, Legal Branch Chief
Sandra B. Hunter, Attorney-Advisor
Re:
Hudson Pacific Properties, Inc.
Registration Statement on Form S-3
File No. 333-175326
Ladies and Gentlemen:
On behalf of Hudson Pacific Properties, Inc. (the “Company”), we have electronically transmitted for filing under separate cover, pursuant to Regulation S-T, Amendment No. 1 (the “Amendment”) to the Company’s above-referenced Registration Statement on Form S-3, which was initially filed with the Securities and Exchange Commission (the “Commission”) on July 1, 2011 (the “Registration Statement”). For your convenience, we have enclosed a courtesy package that includes five copies of the Amendment, three of which have been marked to show changes from the initial filing of the Registration Statement on July 1, 2011.
This letter responds to the comments of the staff (the “Staff”) of the Division of Corporation Finance of the Commission, received by electronic mail on July 14, 2011 (the “Comment Letter”), with respect to the Registration Statement, and the Amendment has been revised to reflect the Company’s responses to the Comment Letter. For ease of review, we have set forth below each of the numbered comments of your letter and the Company’s responses thereto. All page numbers and captions in the responses below refer to the Amendment, except as otherwise noted below.
General
1. Please amend your registration statement to provide the undertakings required by Item 512(a)(5) of Regulation S-K.
Response: The Company has revised Item 17 of Part II of the Registration Statement in response to the Staff’s comment.
* * * *
July 15, 2011
Page 2
Please do not hesitate to contact me by telephone at (213) 891-8371 or by fax at (213) 891-8763 with any questions or comments regarding this correspondence.
Very truly yours,
/s/ Julian T.H. Kleindorfer
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CORRESP 1 filename1.htm Correspondence Letter 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 July 15, 2011 Chicago Paris Doha Riyadh Dubai Rome Frankfurt San Diego VIA EDGAR AND OVERNIGHT COURIER Hamburg San Francisco Hong Kong Shanghai Securities and Exchange Commission Houston Silicon Valley Division of Corporate Finance London Singapore Mail Stop 4631 Los Angeles Tokyo 100 F Street, N.E. Madrid Washington, D.C. Washington, D.C. 20549 Milan Attention: Tom Kluck, Legal Branch Chief Sandra B. Hunter, Attorney-Advisor Re: Hudson Pacific Properties, Inc. Registration Statement on Form S-3 File No. 333-175326 Ladies and Gentlemen: On behalf of Hudson Pacific Properties, Inc. (the “Company”), we have electronically transmitted for filing under separate cover, pursuant to Regulation S-T, Amendment No. 1 (the “Amendment”) to the Company’s above-referenced Registration Statement on Form S-3, which was initially filed with the Securities and Exchange Commission (the “Commission”) on July 1, 2011 (the “Registration Statement”). For your convenience, we have enclosed a courtesy package that includes five copies of the Amendment, three of which have been marked to show changes from the initial filing of the Registration Statement on July 1, 2011. This letter responds to the comments of the staff (the “Staff”) of the Division of Corporation Finance of the Commission, received by electronic mail on July 14, 2011 (the “Comment Letter”), with respect to the Registration Statement, and the Amendment has been revised to reflect the Company’s responses to the Comment Letter. For ease of review, we have set forth below each of the numbered comments of your letter and the Company’s responses thereto. All page numbers and captions in the responses below refer to the Amendment, except as otherwise noted below. General 1. Please amend your registration statement to provide the undertakings required by Item 512(a)(5) of Regulation S-K. Response: The Company has revised Item 17 of Part II of the Registration Statement in response to the Staff’s comment. * * * * July 15, 2011 Page 2 Please do not hesitate to contact me by telephone at (213) 891-8371 or by fax at (213) 891-8763 with any questions or comments regarding this correspondence. Very truly yours, /s/ Julian T.H. Kleindorfer Julian T.H. Kleindorfer of LATHAM & WATKINS LLP Enclosures cc: Mark T. Lammas, Hudson Pacific Properties, Inc. Kay L. Tidwell, Hudson Pacific Properties, Inc. 2