VIA EDGAR SUBMISSION
July 26, 2017
Ms. Shannon Sobotka
Staff Accountant
Office of Real Estate & Commodities
U.S. Securities and Exchange Commission
100 F Street, NE
Washington, D.C. 20549
| Re: | Columbia Property Trust, Inc. | |
| Form 10-K for the fiscal year ended December 31, 2016 | ||
| Filed February 9, 2017 | ||
| File No. 1-36113 | ||
Dear Ms. Sobotka:
On behalf of Columbia Property Trust Inc., a Maryland corporation (the “Company”), we are responding to the comments of the staff of the Division of Corporation Finance (the “Staff”) of the Securities and Exchange Commission (the “Commission”) as set forth in your letter dated July 14, 2017 relating to the Company’s Form 10-K for the fiscal year ended December 31, 2016, which was filed with the Commission on February 9, 2017.
For ease of reference in this letter, your comments appear in italics directly above the Company’s responses.
Financial Statements
15. Segment Information, page F-35
| 1. | We note the company’s change in reportable segments and that you consider geographic location when evaluating your portfolio composition and in assessing ongoing operations and performance of your properties. However, we note your results of operations discussion continues to be presented on a consolidated basis. Please tell us why you do not also provide a discussion by reportable segment. Reference is made to Rule 3-03(a) of Regulation S-K. |
Response:
The Company acknowledges the Staff’s comment and will include additional discussion of NOI by geographic segment in the Company’s discussion of results of operations in future filings, beginning with the Company’s Quarterly Report on Form 10-Q for the three months ended June 30, 2017.
One Glenlake Parkway Suite 1200 Atlanta, GA 30328 columbia.reit | T 800 899 8411 T 404 465 2200 F 404 465 2201 | |
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If we can be of any assistance in explaining these responses, please let us know. Please contact me with any questions or comments at (404) 465-2200.
Very truly yours,
/s/ James A. Fleming
James A. Fleming
Chief Financial Officer
| cc: | Isaac Esquivel, Securities and Exchange Commission |
| Jerard Gibson, Securities and Exchange Commission | |
| Jennifer Gowetski, Securities and Exchange Commission | |
| Alan Prince, King & Spalding LLP | |
| Mark Scalese, Deloitte & Touche LLP | |