September 23, 2015
VIA EDGAR
United States Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, D.C. 20549
Attention: Tom Kluck – Legal Branch Chief
Mail Stop 4561
| Re: | Franklin Street Properties, Inc. |
| Form 10-K | |
| Filed February 17, 2015 | |
| File No. 001-32470 |
Dear Mr. Kluck:
Franklin Street Properties Corp. (the “Company”) has set forth below a response to the comment to the Company’s Annual Report on Form 10-K for the year ended December 31, 2014 provided by you to Mr. John G. Demeritt in a letter dated September 15, 2015 (the “Letter”). The response is keyed to the numbering of the comment in the Letter and to the headings used in the Letter.
Item 2. Properties
1. In future Exchange Act periodic reports, please provide a lease expiration table for ten years, starting with the year in which the report is filed, stating (i) the number of tenants whose leases will expire, (ii) the total area in square feet covered by such leases, (iii) the annual rental represented by such leases, and (iv) the percentage of gross annual rental represented by such leases.
Response
In future Annual Reports on Form 10-K, the Company undertakes to include a lease expiration table for ten years, starting with the year in which the report is filed, stating (i) the number of tenants whose leases will expire, (ii) the total area in square feet covered by such leases, (iii) the annual rental represented by such leases, and (iv) the percentage of gross annual rental represented by such leases.
FSP Investments LLC ▪ FSP Property Management LLC
401 Edgewater Place ▪ Suite 200 ▪ Wakefield, MA 01880 ▪ Telephone: 781 246 4900 ▪ Fax: 781 246 2807
United States Securities and Exchange Commission
Attn: Tom Kluck – Legal Branch Chief
September 23, 2015
Page 2
The Company hereby acknowledges that:
| (i) | it is responsible for the adequacy and accuracy of the disclosure in the filing; |
| (ii) | 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 |
| (iii) | 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. |
Please feel free to call me at (781) 557-1341 with any questions or comments concerning this response.
Very truly yours,
/s/ John G. Demeritt
John G. Demeritt
Executive Vice President and Chief Financial Officer
| cc: | Scott H. Carter, Esq., Executive Vice President, General Counsel and Secretary, Franklin Street Properties Corp. |
| Kenneth A. Hoxsie, Esq., WilmerHale | |
| Mr. Robert Hatch, Ernst & Young LLP |