2014 Q2 Corresp re10-K 6-18-14



	545 E. JOHN CARPENTER FREEWAY, SUITE 1300 IRVING, TX 75062 PH: 972-444-4900 F: 972-444-4949 WWW.FELCOR.COM NYSE:FCH

JEFFREY D. SYMES

Senior Vice President

Chief Accounting Officer and Controller

June 18, 2014

VIA EDGAR

U.S. Securities and Exchange Commission

Division of Corporation Finance

100 F Street, NE

Washington, D.C. 20549



Re:	FelCor Lodging Trust Incorporated
	Form 10-K for the year ended December 31, 2013
	File No. 1-14236

	FelCor Lodging Limited Partnership
	Form 10-K for the year ended December 31, 2013
	File No. 333-39595-01

Ladies and Gentlemen:

On behalf of FelCor Lodging Trust Incorporated and FelCor Lodging Limited Partnership (collectively “FelCor”), we hereby file FelCor's response to comments contained in the letter from the U.S. Securities and Exchange Commission, Division of Corporation Finance; (the “Commission”) dated June 12, 2014. For your convenience, we have repeated each comment prior to the response.

Form 10-K for the year ended December 31, 2013

Item 15. Exhibits and Financial Statement Schedules, page 116

Schedule III - Real Estate and Accumulated Depreciation, page 109


1.	Please provide us with reconciliations of total cost of land, building and improvements, as well as the related accumulated depreciation in Schedule III, to the related amounts on the balance sheet and/or the related amounts in Note 3.

U.S. Securities and Exchange Commission

June 18, 2014

Page 2

Please see below reconciliation:



Reconciliation of Note 3 to Schedule III
(in thousands)


Information as Included in Note 3:
	December 31,			December 31,
	2013			2012

Building and improvements	$	1,833,165		$	1,962,164
Furniture, fixtures and equipment	482,628			488,237
Land	234,447			248,614
Construction in progress	32,828			24,847
	2,583,068			2,723,862
Accumulated depreciation	(929,801		)	(929,298		)
Investment in hotels, net of accumulated depreciation (per Balance Sheet and Note 3)	$	1,653,267		$	1,794,564



Accumulated Depreciation components:

Accumulated Depreciation - Building and improvements (per Schedule III)	$	(698,146	)	$	(693,114	)
Accumulated Depreciation - Furniture, Fixtures and Equipment	(231,655		)	(236,184		)
Total Accumulated Depreciation (per Balance Sheet and Note 3)	$	(929,801	)	$	(929,298	)



Reconciliation of Total Land, Building and Improvements per Note 3 to Schedule III:

Building and improvements (per Note 3)	$	1,833,165		$	1,962,164
Land (per Note 3)	234,447			248,614
Total Land, Building and improvements (per Note 3)	$	2,067,612		$	2,210,778
Rounding differences^(a)	(4		)	(3		)
Total Land, Building and improvements (per Schedule III)	$	2,067,608		$	2,210,775

(a) Rounding differences will be eliminated in future filings.

545 E. JOHN CARPENTER FREEWAY, SUITE 1300

IRVING, TX 75062

PH: 972-444-4900 F: 972-444-4949

WWW.FELCOR.COM

U.S. Securities and Exchange Commission

June 18, 2014

Page 3

* * * *

We acknowledge the following:


•	FelCor 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


•	FelCor 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.

If any members of the staff have any questions concerning the above responses or desire further information or clarification in connection therewith, he or she should contact me at 972-444-4925.

Sincerely,

/s/Jeffrey D. Symes

Jeffrey D. Symes

Senior Vice President

Chief Accounting Officer and Controller



cc:	Michael C. Hughes, Chief Financial Officer, FelCor Lodging Trust Incorporated
	Jonathan H. Yellen, General Counsel, FelCor Lodging Trust Incorporated
	Robert W. Dockery, Akin Gump Strauss Hauer & Feld L.L.P.

545 E. JOHN CARPENTER FREEWAY, SUITE 1300

IRVING, TX 75062

PH: 972-444-4900 F: 972-444-4949