August 2, 2019
Peter Seymour
Chief Financial Officer
Douglas Emmett, Inc.
1299 Ocean Avenue
Suite 1000
Santa Monica, CA 90401
Re: Douglas Emmett, Inc.
Form 10-K for the year ended December 31, 2018
Filed February 15, 2019
File No. 001-33106
Dear Mr. Seymour:
We have reviewed your filing and have the following comment. In our
comment, we
may ask you to provide us with information so we may better understand your
disclosure.
Please respond to the comment within ten business days by providing the
requested
information or advise us as soon as possible when you will respond. If you do
not believe our
comment applies to your facts and circumstances, please tell us why in your
response.
After reviewing your response to the comment, we may have additional
comments.
Form 10-K for the year ended December 31, 2018
Note 1. Overview
Basis of Presentation, page F-9
1. We note that you have consolidated JVs for which you are the primary
beneficiary.
Please tell us how you have met the disclosure requirements of ASC
810-10-50-5A or
revise accordingly in future filings.
We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence of
action by the staff.
Peter Seymour
Douglas Emmett, Inc.
August 2, 2019
Page 2
You may contact Babette Cooper, Staff Accountant, at 202-551-3396 or
Kristi Marrone,
Staff Accountant, at 202-551-3429 if you have questions regarding comments on
the financial
statements and related matters or any other questions.
Sincerely,
FirstName LastNamePeter Seymour
Division of
Corporation Finance
Comapany NameDouglas Emmett, Inc.
Office of Real Estate
and
August 2, 2019 Page 2 Commodities
FirstName LastName