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                            October 19, 2022

       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
Year Ended December 31, 2021
                                                            Filed March 1, 2022
                                                            File No. 001-32559

       Dear R. Steven Hamner:

               We have reviewed your September 28, 2022 response to our comment
letter 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. Unless we note otherwise, our references to prior comments are
to comments in our
       September 14, 2022 letter.

       Form 10-K for the Year Ended December 31, 2021

       Significant Tenants, page 12

   1.                                                   We note your response
to comment 1 indicated that assets leased to
                                                        Steward represented
17.8% of your total assets as of December 31, 2021, after exclusion
                                                        of assets related to
the Macquarie Transaction. Please address the following:
                                                            As part of the
Macquarie Transaction, you received a 50% interest in the joint venture
                                                             that now holds the
eight Massachusetts-based hospitals that are leased to Steward.
                                                             Please clarify for
us whether or not your 17.8% result includes your 50% interest in
                                                             this joint
venture.
                                                            To the extent that
you have excluded your 50% interest in this joint venture from
 R. Steven Hamner
FirstName LastNameR.
Medical Properties Trust,Steven
                          Inc. Hamner
Comapany
October 19,NameMedical
            2022           Properties Trust, Inc.
October
Page 2 19, 2022 Page 2
FirstName LastName
              your significance calculation, please tell us why you feel it is
appropriate to do so
              when analyzing the significance of the Steward concentration.
                Please provide us with your significance calculation that
details any adjustments
              made to the assets leased by Steward as of December 31, 2021.
                Additionally, tell us if your joint venture partner, Macquarie
Asset Management, is an
              affiliated entity of Medical Properties Trust, Inc. or its
subsidiaries or has ties to any
              of your officers or board members.
2.       We note your response to our comment 2. Please address the following:
             It appears that you have adjusted the line items for Steward and
HCA within your
            table on page 12 for a pending transaction for amounts that are not
reflected in your
            reconciliation on page 49; please confirm or clarify.
             Other than the Steward and HCA pending transaction noted above and
the
            adjustments in the reconciliation on page 49, please clarify for us
if any individual
            line items in your table on page 12 reflect any additional
adjustments.
             To the extent you have adjustments to any individual line items
within the total
            adjusted gross assets by operator table that are not reflected in
your reconciliation
            from total assets to total adjusted gross assets, please confirm
that you will expand
            your disclosure in future filings to provide more quantitative and
qualitative
            information about any such adjustments.
             Please provide a more robust explanation of how you determined it
was appropriate
            to reflect the impact from the pending transaction related to
Steward and HCA within
            your table. Within your response, please address the length of time
until you
            expected the transaction to close and your consideration of the
regulatory approvals
            that were still pending.
Item 7. Management's Discussion and Analysis of Financial Condition and Results
of Operations
Non-GAAP Financial Measures
Pro Forma Gross Assets, page 49

3.       We note your response to our comment 4. Please address the following:
             Please tell us and revise future filings to provide more
qualitative and quantitative
            information related to the line item 'cash used for funding the
transactions above (4)'
            in your table at the bottom of page 49. In this regard, please
quantify and
            describe each material component that results in the total
adjustments of $1,377,299
            and $587,384 for this line item.
             Please further clarify for us and in future filings how the
amounts for the line item
            'incremental gross assets of our joint ventures and other (3)' are
derived.
 R. Steven Hamner
Medical Properties Trust, Inc.
October 19, 2022
Page 3

       You may contact Howard Efron at 202-551-3439 or Jennifer Monick at
202-551-3295 if
you have questions regarding comments on the financial statements and related
matters.



FirstName LastNameR. Steven Hamner                     Sincerely,
Comapany NameMedical Properties Trust, Inc.
                                                       Division of Corporation
Finance
October 19, 2022 Page 3                                Office of Real Estate &
Construction
FirstName LastName