SecProbe.io

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-4631

       DIVISION OF
CORPORATION FINANCE

 Mail Stop 4631

VIA FACSIMILE AND U.S. MAIL

 September 15, 2009

Laurence A. Tosi Chief Financial Officer The Blackstone Group L.P. 345 Park Avenue
New York, New York 10154

 RE: The Blackstone Group L.P.
Form 10-Q for Period Ended June 30, 2009
File No. 1-33551

Dear Mr. Tosi:
   We have reviewed your filing and have  the following comments.  Please be as
detailed as necessary in your explanation, and where you believe we have raised an
immaterial issue, please expl ain the basis for your view.  We have asked you to provide
us with supplemental information so we may better understand your views and/or disclosure better.  After reviewing this information, we may or may not raise additional
comments on the matter.   Please understand that the purpose of our re view process is to assist you in your
compliance with the applicable disclosure re quirements and also in  the enhancement of
the overall disclosure in the filing.  We w ill make every effort to accommodate timing
considerations that you may have, subject to our overall workload priorities.  In this
regard, it will be helpful if you can keep us apprised of developments in your schedule
and if you can respond to our comments and inqu iries as quickly as possible.  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 fr ee to call us at the telephone numbe rs listed at the end of this
letter.

Mr. Laurence Tosi
September 15, 2009
Page 2
FORM 10-Q FOR THE PERIOD ENDED JUNE 30, 2009

 Management’s Discussion and Analysis of Fi nancial Condition and Results of Operations

1. In your analysis of performance fees on page 48 you note that the increase was
“principally driven by positive performance in one of our private equity investment funds”.  We also note references to perfor mance in “certain funds” or other individual
funds elsewhere in your analysis.  As you know, in our letter dated October 31, 2008,
we asked you to consider providing f und performance information in your
disclosures.  In your response dated December 5, 2008, you stated that such
information is not a meaningful measuremen t of your results of operations. In order
for us to better understand this view, and th e factors that have impacted your results
of operations, we respectfully request that  you provide us with certain supplemental
information as indicated in the comments that follow below.
2. In your response letter dated May 21, 2007 (pursuant to you r registration statement on
Form S-1), you provided us with a listing of all of your funds. Pl ease provide us with
such a list as of June 30, 2009.  Please indicate whether or not each fund is
consolidated in your financial statements as of that date. Please include an additional
column that presents the assets under management (AUM) by fund.
3. Please tell us whether the fa ir value of any individual f und represented more than 5%
of segment AUM at any year-end for the three years ended December 31, 2008, or as
of June 30, 2009.
4. Please tell us whether any of the following measures, either separately or combined,
for any individual fund, has impacted the segment Economic Net Income (Loss) of
any segment, by more than 5% in any of  the three years ended December 31, 2008, or
in the six month peri od ended June 30, 2009:
• Management and advisory fees earned;
• Gross performance f ees and allocations;
• Gross reversals of performan ce fees and allocations; and
• Investment income (loss)
5. Please tell us whether any of the followi ng measures, for any individual fund, was
greater than 5% of beginning or ending segm ent AUM in any of the three years ended
December 31, 2008, or in the six month period ended June 30, 2009:
• Inflows (contributions and increases in available capital);
• Outflows (redemptions, dispositions a nd decreases in available capital); and
• Market appreciation depreciation

Mr. Laurence Tosi
September 15, 2009
Page 3
6. For each of your funds that met the criteria de scribed in comments three, four or five
by more than 5%, please provide us with the following for any period(s) specified:
• Identify the investment fund;
• Identify and describe the underlying investments in the fund;
• Identify the above criteria and reporting period(s) in which the specified criteria
was met;
• Quantify each of the above criteria for each of the three years ended December
31, 2008 and the six months ended June 30, 2009;
• Provide us with the annual returns and the retu rns from inception to date for each
fund, for each of the three years ende d December 31, 2008 and the six months
ended June 30, 2009; and
• Provide us with enhanced na rrative analysis discussing any material activity in
each of those funds, for each of the th ree years ended December 31, 2008 and the
six months ended June 30, 2009.

  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.  Pleas e submit your response on EDGAR as a
correspondence file.  Please understand that we may have additional comments after
reviewing your responses to our comments.
We urge all persons who are responsible for the accuracy and adequacy of the
disclosure in the filing to be certain that the filing includes all in formation required under
the Securities Exchange Act of 1934 and th at they have provided all information
investors require for an informed invest ment decision.  Since the company and its
management are in possession of all facts re lating to a company’s disclosure, they are
responsible for the accuracy and adequacy of the disclosures they have made.

 In connection with responding to our comments, please provide, in writing, a statement from the company acknowledging that:
• the company is responsible for the adequacy and accuracy of the disclosure in their filings;
• 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; and
• the company may not assert staff comme nts as a defense in any proceeding
initiated by the Commission or any pers on under the federal s ecurities laws of
the United States.

Mr. Laurence Tosi
September 15, 2009 Page 4
In addition, please be advise d that the Division of Enfo rcement has access to all
information you provide to the staff of the Divi sion of Corporation Fi nance in our review
of your filing or in response to our comments on your filing.
You may contact Lisa Haynes, Staff A ccountant, at (202) 551-3424, or in her
absence, myself at (202) 551-3689, if you ha ve questions regarding comments on the
financial statements and related matters.

 Sincerely,           John Hartz
      Senior Assistant Chief Accountant