July 12, 2024

Gavin B. Brandon
Chief Financial Officer
Orion Office REIT Inc.
2398 E. Camelback Road, Suite 1060
Phoenix, AZ 85016

       Re: Orion Office REIT Inc.
           Form 10-K for the Fiscal Year ended December 31, 2023
           Response dated May 8, 2024
           File No. 001-40873
Dear Gavin B. Brandon:

       We have reviewed your May 8, 2024 response to our comment letter and
have the
following comment.

       Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in your
response.

        After reviewing your response to this letter, we may have additional
comments. Unless we
note otherwise, any references to prior comments are to comments in our April
26, 2024 letter.

Form 10-K for the year ended December 31, 2023
Item 2. Properties, page 25

1.     We note your response to prior comment 5. As previously stated, please
tell us, and in
       future filings, please disclose, the class of office buildings in each
portfolio, or advise.
       Please contact Peter McPhun at 202-551-3581 or Jennifer Monick at
202-551-3295 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Kibum Park at 202-551-6836 or Dorrie Yale at 202-551-8776 with any
other questions.



                                                              Sincerely,

                                                              Division of
Corporation Finance
                                                              Office of Real
Estate & Construction