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

       DIVISION OF
CORPORATION FINANCE

Mail Stop 4631

 VIA FACSIMILE AND U.S. MAIL

 November 20, 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.
Forms 10-Q for Periods Ended Sept ember 30, 2009 an d June 30, 2009
File No. 1-33551

Dear Mr. Tosi:

 We have reviewed your response dated September 29, 2009 and have the
following comments.  Where indicated, we think you should revise your document 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.  Please be as detailed as
necessary in your explanation.  In some of our comments, we have asked you to provide
us with supplemental information so we ma y better understand your disclosure.  After
reviewing this information, we may raise additional comments.
  Please understand that the purpose of our re view process is to assist you in your
compliance with the applicable disclosure requirements and to enhance the overall disclosure in your  filing.  We look forward to working with you in these respects.  We
welcome any questions you may have about our comments or any other aspect of our review.  Feel free to call us at the telephone numbers listed at the end of this letter.

General

1. We appreciate your response to our lette r dated September 15, 2009, and our related
discussion on November 4, 2009.  Based on your response and our conversation, we ask that you provide expanded disclosures concerning the perfor mance of, fees in,
and activity in, significant funds in order to  provide more meaningful and transparent
information to readers.

Mr. Laurence Tosi
November 20, 2009
Page 2  Business: Fund Performance Information

2. Please expand disclosures in future filings  to provide readers with a meaningful
understanding of the performance of each of your significant funds. Although you are
in the best position to determine which funds those may be, we ask that you consider the following criteria. The fund:
• Had, or is expected to have, a material impact on management fees, or incentive
fees in relation to segment results;
• Comprises a material amount of segment AUM;
• Had, or is expected to have, material i nvestments, or redemptions in relation to
segment AUM; or
• Had, or is expected to have, material a ppreciation, or depreciation in relation to
segment AUM.

3. For each significant fund, please identify the fund and describe the underlying types
of investments and overall strategy involve d in the fund.  Disclose the annualized
returns for the periods presented, and incepti on to date returns, for both returned and
unreturned funds.  Please clearl y explain that the returns are those of the funds and
not those of The Blackstone Group, L.P.
 Management’s Discussion and Analysis of Fi nancial Condition and Results of Operations

4. We note from your response that for each  period presented, the changes in
management fees, performance fees/reversals  and the investment income of certain
funds appear to have had a significant impact on your segment Economic Net Income or Loss.  We believe that a more rigor ous discussion, including identification of
particular funds and the re lated changes described a bove, would provide a more
meaningful discussion to readers.  Th at discussion may also include, for any
individual fund, if material:
• Whether a specific threshold and/or realiz ation event has been met in determining
any incentive fee, if applicable;
• The reasonable likelihood of a ttaining the thresholds in future periods. This could
include a discussion about the high-water marks on a fund; and
• The amount of actual revers als recorded and potential claw-backs. For example,
quantifying the amount of claw-backs that would be required to be repaid if the
fund were liquidated at its net asset value.
 5. As we discussed, if information about a specific investment he ld within a fund is
material to an understanding of your resu lts of operations, you will identify that
investment and quantify the impact such  investment had during the period, or
otherwise disclose any material information concerning that specific investment.  On
a forward-looking basis, if information about a specific investment is material to an
understanding of your future operations , please disclose that information.

Mr. Laurence Tosi
November 20, 2009 Page 3  6. If in the future, you experience inflows, out flows or market appreciation/depreciation
that have a significant impact on your fees or AUM, provide a discussion about that
activity, and where material, identify the particular funds and their impact. That discussion should also include for any individual f und, if material:
• The policy concerning redemptions.  For ex ample, disclose whether shareholders
of funds are required to give advance no tice prior to redemption and if so, the
extent of notice required.  Disclose  whether you have suspended redemption
requests. Provide an explanation for any suspensions and when you expect to lift
the suspension; and
• The extent of any significant changes in  AUM after the balance sheet date but
prior to filing your Form 10-K or 10-Q.  Quantify the portion of the change that
was attributable to performance as opposed to redemptions/investments.  Disclose which investment types, segments, or  individual investments were most
significantly impacted.  For any of thes e significant change s, disclose and
quantify the impact on future result s of operations and cash flows.
 7. Based on our discussion, you have agreed to make these disclosures in your Form 10-
K for the year ended December 31, 2009 and to  provide us with sample disclosures
reflecting the above changes for the th ird quarter ended September 30, 2009.  We
look forward to your response to these co mments and the sample disclosures.
   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.
You may contact Lisa Haynes, Staff A ccountant, at (202) 551-3424 or me at
(202) 551-3689, if you have questions regard ing comments on the financial statements
and related matters.

 Sincerely,           John Hartz
      Senior Assistant Chief Accountant