Mail Stop 4561
	 								May 30, 2006

VIA U.S. MAIL AND FAX (858) 485-9843

Mr. Alan D. Gold
President and Chief Executive Officer
Biomed Realty Trust, Inc.
17140 Bernardo Center Drive, Suite 222
San Diego, CA 92128

      Re:	Biomed Realty Trust, Inc.
      	Form 10-K for the year ended December 31, 2005
      	Filed March 15, 2006
      File No. 1-32261

Dear Mr. Gold:

      We have reviewed your filing and have the following
comments.
We have limited our review of your filing to those issues we have
addressed in our comments.  Please be as detailed as necessary in
your explanations.  In some of our comments, we may ask you to
provide us with information so we may better understand your
disclosure.  After reviewing this information, we may raise
additional comments.

	Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or any other aspect
of
our review.  Feel free to call us at the telephone numbers listed
at
the end of this letter.

Form 10-K for the year ended December 31, 2005

Consolidated Statements of Income, page 53
1. In future filings, please revise the presentation of your
statements of operations to display expenses related to Tenant
recovery income on a disaggregated basis.  For example,
disaggregate
Rental operations expense to show the portion related to Tenant
recovery income.  See paragraph 3 of EITF 99-19.



14.  Property Acquisitions, page 77
2. In future filings, for periods in which a material business
combination has been completed, provide the pro forma information
required by paragraphs 54 and 55 of SFAS 141, for the current
period,
and the comparable prior period as described therein.

*    *    *    *

      As appropriate, please respond to these comments within 10
business days or tell us when you will provide us with a response.
Please furnish a cover letter with your response that keys your
responses to our comments and provides any requested information.
Detailed cover letters greatly facilitate our review.  Please
understand that we may have additional comments after reviewing
your
responses to our comments.

	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 all information required under the Securities
Exchange Act of 1934 and that they have provided all information
investors require for an informed investment decision.  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.

	In connection with responding to our comments, please
provide,
in writing, a 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.

      In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in our review of your filing or in
response to our comments on your filing.


      If you have any questions, you may contact Eric McPhee at
(202)
551-3693 or me at (202) 551-3498.

     Sincerely,



           Linda van Doorn
     Senior Assistant Chief Accountant


Mr. Alan D. Gold
Biomed Realty Trust, Inc.
May 30, 2006
Page 1