SecProbe.io

August 11, 2015
Mail Stop 4546

Via E -mail
Antony P. Ressler
Chairman a nd Chief Executive Officer
Ares Management, L.P.
2000 Avenue of the Stars, 12 th Floor
Los Angeles, CA  90067

Re: Ares Management, L.P.
 Form 10-K for the Fiscal Year Ended December 31, 2014
 Filed March 20, 2015
File No. 001-36429

Dear Mr. Ressler :

We have reviewed your filing an d 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 busine ss days by providing the requested
information or advis e 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, 2014

Item 7.   Management’s Discussion and Analysis of Financial Condition and Results of
Operation s, page 100

Results of Operations by Segment, page 125

Tradable Credit Group – Fund Performance Metrics as of December 31, 2014, page 134

1. In an effort to provide trans parency and insight into recent trends in your performance
fees (incentive fees), please revise your future filings to include a table (by fund, and in
comparable format) that presents your accrued incentive fees, realized gains/losses, and
unrealized gain s/losses, and reconcile these disclosures to your accrued incentive fees and
segment performance fees as provided elsewhere in your report ( e.g., pages 125 and 262).
Where information is currently provided (in part), it may be necessary to expand your

Antony P. Ressler
Ares Management, L.P.
August 11, 2015
Page 2

 threshold for significance to provide a sufficient level of granularity.  Provide this
information for all of your segments.

Item 8.  Financial Statements and Supplementary Data, page 180

Note 3.  Goodwill and Intangible Assets, page 205

Business Combinations, page 205

2. We note that you acquired interest s in Keltic Financial Services, LLC in June 2014 and
AREA Sponsor Holdings, LLC and AREA Management Holdings, LLC in July 2013.
Please explain why you have not provided the disclosures required by ASC 805 -10-50-
2h.  Please advise or revise your disclosure in future filings as necessary.

Note 9.  Redeemable and Non -Controlling Interests, page 241

3. We note your tables on pages 242 and 243 representing the changes in your Redeemable
Interests in A res Operating Group Entities and Non -Controlling Interests in Ares
Operating Group Entities, respectively.  Please explain to us the nature of the “tandem
award compensation adjustment(s)” and provide us with a discussion of your accounting
analysis and th e authoritative guidance you used to support your accounting treatment.  In
addition, expand your disclosure within Note 2 on page 196 (Redeemable Interest in Ares
Operating Group Entities) in your future filings to discuss the nature and terms of the
tandem award compensation arrangement.

Note 15.  Equity Compensation, page 253

4. We note that the Indicus Partners have a put option and that you have recognized a n
equity  compensation put option liability ($20.0 million) in the Consolidated Statements
of Financial Condition at December 31, 2014.  We also note that the aggregate settlement
amount was $40.0 million at December 31, 2013; however, it is not clear how the put
option was recognized in the corresponding period.  Please explain your accounting
analysis for the put option liability at Dece mber 31, 2013 and how, or if, the analysis
differed at December 31, 2 014.  Provide us with the authoritative literature you used to
support your accounting treatment.

We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing s to be certain that the filing s includ e the information the Securities Exchange Act of
1934 and all applicable Ex change Act rules require.   Since the company and its management are
in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.

Antony P. Ressler
Ares Management, L.P.
August 11, 2015
Page 3

  In responding to our comments, plea se provide a written statement from the company
acknowledging that:

 the company is responsible for the adequacy and accuracy of the disclosure in the filing s;

 staff comments or changes to disclosure in response to staff comments do not foreclose
the Commission from taking any action with respect to the filing s; and

 the company may not assert staff comments as a defense in any proceeding initiated by
the Commission or any person under the federal securities laws of the United States.

You may contact Michelle Miller at (202) 551-3368  or me at (202) 551 -3872  with any
questions.

Sincerely,

/s/ Hugh West

Hugh West
Accounting Branch Chief
Office of Financial Services II