Mail Stop 4561
	 								June 9, 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 response letter filed June 6, 2006 and
have the following additional comment.  Please be as detailed as
necessary in your explanation.  In our comment, we may ask you to
provide us with information so we may better understand your
disclosure.  After reviewing this information, we may or may not
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 comment or on 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

14.  Property Acquisitions, page 77

We note your response to our comment #2.  Please clarify for us
how
you evaluated the acquisitions during 2005 under EITF 98-3 to
determine that none of the transactions constituted the purchase
of a
business.  We note that you have included the proforma results of
operations for your significant acquisitions on Forms 8-K.

*    *    *    *

      As appropriate, please respond to this comment 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
response to our comments.

      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.
June 9, 2006
Page 1