SecProbe.io

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-7010

       DIVISION OF
CORPORATION FINANCE

VIA FACSIMILE AND U.S. MAIL

                                                                             January 7, 2009
 Michael A. Puglisi Chief Financial Officer The Blackstone Group L.P. 345 Park Avenue New York, New York 10154
 RE: The Blackstone Group L.P.
Form 10-K for Fiscal Year  Ended December 31, 2007
Forms 10-Q for Fiscal Quarters E nded March 31, 200 8, June 30, 2008
and September 30, 2008 File No. 1-33551

Dear Mr. Puglisi:

We have reviewed your response letter  dated December 5, 2008 and have the
following comments.  Where indicated, we th ink you should revise your disclosures in
response to these comments.  If you disagree , we will consider your explanation as to
why our comment is inapplicable or a revisi on is unnecessary.  Pleas e be as detailed as
necessary in your explanation.  Please understand that the pur pose of our review process
is to assist you in your compliance with the applicable disclosure requirements and to
enhance the overall disclosure in your fili ng.  We look forward to working with you in
these respects.  We welcome any questions you may have about our comments or on any other aspect of our review.  Feel free to call us at the phone numbers listed below.

FORM 10-K FOR THE YEAR ENDED DECEMBER 31, 2007

 General

1. Where a comment below requests additional disclosures or other revisions to be
made, please show us in your supplemental response what the revisions will look like.  These revisions should be include d in your future filings, including your
interim filings.

Mr. Michael Puglisi
January 7, 2009 Page 2  Management’s Discussion and Analysis of Financial Condition and Results of
Operations, page 53
 General

 2. We have read your response to comment three from our letter dated October 31,
2008. You indicate that you will disclose th e activity between the beginning and
ending balances of assets under management as shown in Appendix A.  With regards to outflows/redemptions, please disclose how much notice you require for
an investor to request a redemption.  Pleas e also quantify to the extent possible,
information regarding any known changes in assets under management occurring subsequent to your latest balance sheet da te but prior to the date of your filings,
such as known redemptions and/ or no tices of expected redemptions.  Your
disclosures should clearly reflect any know n trends in redemptions or notice of
expected redemptions within MD&A.
 Critical Accounting Policies, page 76

 Investments, at Fair Value, page 77

 3. We have read your response to comment nine from our letter dated October 31,
2008.  You indicate in Exhibit D that the determination of fair value involves a
significant degree of management’s j udgment taking into consideration a
combination of internal and external f actors, including the appropriate risk
adjustments for non-performance and liquidity  risks.  To the extent material to
your own facts and circumstances, please expand your disclosure to provide the
following:
• The criteria you used to determine whether the market for a financial
instrument is active or in active (i.e., illiquid); and
• Differentiate, if applicable, between y our methods for determining fair value
for illiquid instruments as compared to investments without observable market
prices.  To the extent applicable, plea se describe which financial instruments
are affected by the lack of  market liquidity (i.e. in activity), how the lack of
liquidity impacted the valuation t echnique you used, and how you factored
illiquidity into your fair value determination of thos e financial instruments.
For example, to the extent you used a discounted cash flow approach to
determine the fair value of a financia l instrument, such as auction rate
securities, loans held for sale, or mortgage-backed securities backed by
subprime or Alt-A collateral, consider discussing the specif ic change in the
discount rate or any other analysis y ou performed to account for the lack of
liquidity and discuss how and why you changed your assumptions from prior periods.

Mr. Michael Puglisi
January 7, 2009 Page 3  Financial Statements

 10. Income Taxes, page 110

 4. We have read your response to comme nt 13 from our letter dated October 31,
2008 in which you explain the factors considered in determining that no deferred tax valuation allowance was necessary as  of December 31, 2007.  To the extent
that you have significant deferred tax a ssets, GAAP losses, and little or no
valuation allowance in future periods,  please confirm that you will revise your
filing to describe how you determined th at no valuation allowance was necessary
on your deferred tax assets as of each period end.

FORM 10-Q FOR THE QUARTERLY PERIOD ENDED SEPTEMBER 30, 2008

General
 5. Please address the above comments in your interim filings as well.

Liquidity and Capital Resources, page 50

 6. On page 51, the subtotal in your reconcil iation of Net Cash Provided by (Used In)
Operating Activities presented on a GAAP  basis to Adjusted Cash Flow from
Operations also represents  a non-GAAP measure.  Please remove this subtotal
from your reconciliation or provide the disclosures required by Item 10(e) of
Regulation S-K.

*    *    *    *
   Please respond to these comments with in 10 business days, or tell us when you
will provide us with a response.  Please provi de us with a response letter that keys your
responses to our comments and provides a ny requested information.  Detailed letters
greatly facilitate our review .  Please file your response on EDGAR as a correspondence
file.  Please understand that we may have additional comments after reviewing your
responses to our comments.

Mr. Michael Puglisi
January 7, 2009 Page 4
You may contact Andy Schoe ffler, Staff Attorney, at  (202) 551-3748 or, in his
absence, Pamela Long, Assistant Director, at (202) 551-3760 if you have any questions
regarding legal matters.  Please contact Erne st Greene, Staff Accountant, at (202) 551-
3733 or, in his absence, Lisa Haynes, Sta ff Accountant, at (202) 551-3424 if you have
questions regarding comments on the financ ial statements and related matters.
          Sincerely,            R u f u s  D e c k e r
       Accounting Branch Chief