June 17, 2019

R. Steven Hamner
Executive Vice President and Chief Financial Officer
Medical Properties Trust, Inc.
MPT Operating Partnership, L.P.
1000 Urban Center Drive
Suite 501
Birmingham, AL 35242

       Re: Medical Properties Trust, Inc.
           MPT Operating Partnership, L.P.
           Form 10-K for the Fiscal Year Ended December 31, 2018
           File No. 001-32559
           File No. 333-177186
           Filed March 1, 2019

Dear Mr. Hamner:

       We have reviewed your filing and have the following comments. In some of
our
comments, we may ask you to provide us with information so we may better
understand your
disclosure.

       Please respond to these comments 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
comments apply to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to these comments, we may have additional
comments.

Form 10-K for the Fiscal Year Ended December 31, 2018

Significant Tenants, page 10

1.    We note your disclosure on page 10 that Steward operated 39.5% of your
gross assets as
      of December 31, 2018. Given that Steward appears to be a significant
lessee, please tell
      us what consideration you gave to filing audited financial statements of
Steward. In that
      regard, we note your response to comment 3 from our letter dated October
26, 2018,
      where you stated that you expected to file the financial statements of
Steward with your
      Form 10-K or Form 10-K/A for the year ended December 31, 2018.

       We remind you that the company and its management are responsible for
the accuracy
 R. Steven Hamner
Medical Properties Trust, Inc.
June 17, 2019
Page 2

and adequacy of their disclosures, notwithstanding any review, comments, action
or absence of
action by the staff.

       You may contact Babette Cooper, Staff Accountant, at 202-551-3396 or
Jennifer Monick,
Assistant Chief Accountant, at 202-551-3295 with any questions.



                                                          Sincerely,

FirstName LastNameR. Steven Hamner                        Division of
Corporation Finance
                                                          Office of Real Estate
and
Comapany NameMedical Properties Trust, Inc.
                                                          Commodities
June 17, 2019 Page 2
cc:       Kevin Hanna
FirstName LastName