Mail Stop 3233

                                                           December 13, 2018

Via E-mail
R. Steven Hamner
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, 2017
            Filed March 1, 2018
            Form 10-Q for the Quarterly Period Ended September 30, 2018
            Filed November 9, 2018
            File No. 001-32559 and 333-177186

 Dear Mr. Hamner:

       We have reviewed your November 30, 2018 response to our comment letter
and have the
following comments. In our comments, we may ask you to provide us with
information so we
may better understand your disclosure.

       Please respond to our 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 our comments, we may have additional
comments.
Unless we note otherwise, our reference to a prior comment is to a comment in
our October 26,
2018 letter.
 Steven Hamner
Mortgage Properties Trust, Inc. and MPT Operating Partnership, L.P.
December 13, 2018
Page 2

Form 10-Q for the Quarterly Period Ended September 30, 2018

3. Real Estate and Lending Activities

Joint Venture Transactions, page 13

1.     Please clarify for us the nature of the 290 million shareholder loan and
tell us how you
       are accounting for the shareholder loan in connection with the Primotop
joint venture
       transaction. Please reference the authoritative accounting literature
management relied
       upon.


2.     Your disclosure states that your 50% equity investment in the Primotop
joint venture
       transaction is valued at approximately 211 million. In light of your
determination that
       the fair value of the contributed properties is 1.635 billion and the
gross proceeds of
       recently issued related debt was 655 million, please clarify for us how
you determined
       that your 50% equity interest is valued at 211 million. Please reference
the authoritative
       accounting literature management relied upon.


        You may contact Howard Efron, Staff Accountant, at (202) 551-3439 or me
at (202) 551-
3295 if you have questions regarding comments on the financial statements and
related matters.



                                                           Sincerely,

                                                           /s/ Jennifer Monick

                                                           Jennifer Monick
                                                           Assistant Chief
Accountant
                                                           Office of Real
Estate &
                                                           Commodities