Opinion Letter – Outside Counsel – S-8 Registered Securities – Office Depot, Inc.

October 25, 2011

Board of Directors
Office Depot, Inc.
6600 North Military Trail
Boca Raton, FL 33496

Ladies and Gentlemen:

We are acting as counsel to Office Depot, Inc., a Delaware corporation (the
“Company“), in connection with its registration statement on
Form S-8 (the “Registration Statement“), filed with the
Securities and Exchange Commission under the Securities Act of 1933, as amended
(the “Act“) relating to the registration of 24,000,000 shares
of the common stock, par value $0.01 per share (the “Common
Stock“) of the Company (the “Shares“), issuable under
the Office Depot, Inc. 2007 Long-Term Incentive Plan (the “Plan“) as a
result of the Amendment to the Plan dated April 21, 2011. This opinion letter is
furnished to you at your request to enable you to fulfill the requirements of
Item 601(b)(5) of Regulation S-K, 17 C.F.R. § 229.601(b)(5), in connection with
the Registration Statement.

For purposes of this opinion letter, we have examined copies of such
agreements, instruments and documents as we have deemed an appropriate basis on
which to render the opinions hereinafter expressed. In our examination of the
aforesaid documents, we have assumed the genuineness of all signatures, the
legal capacity of all natural persons, the accuracy and completeness of all
documents submitted to us, the authenticity of all original documents, and the
conformity to authentic original documents of all documents submitted to us as
copies (including telecopies). As to all matters of fact, we have relied on the
representations and statements of fact made in the documents so reviewed, and we
have not independently established the facts so relied on. This opinion letter
is given, and all statements herein are made, in the context of the foregoing.

This opinion letter is based as to matters of law solely on the Delaware
General Corporation Law, as amended. We express no opinion herein as to any
other laws, statutes, ordinances, rules, or regulations. As used herein, the
term “Delaware General Corporation Law, as amended” includes the statutory
provisions contained therein, all applicable provisions of the Delaware
Constitution and reported judicial decisions interpreting these laws.

Based upon, subject to and limited by the foregoing, we are of the opinion
that following the issuance of the Shares pursuant to the terms of the Plan and
any applicable award agreements under the Plan, the Shares will be validly
issued, fully paid, and nonassessable.

This opinion letter has been prepared for use in connection with the
Registration Statement. We assume no obligation to advise you of any changes in
the foregoing subsequent to the effective date of the Registration Statement.

We hereby consent to the filing of this opinion letter as Exhibit 5.1 to the
Registration Statement. In giving this consent, we do not thereby admit that we
are an “expert” within the meaning of the Securities Act of 1933, as amended.

Very truly yours,

/s/ HOGAN LOVELLS US LLP

HOGAN LOVELLS US LLP