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SEC Company Response from Blackstone (BX) — Jun 19, 2007

Blackstone Inc.
Date: June 19, 2007 · CIK: 0001393818 · Accession: 0001104659-07-048554

AI Filing Summary & Sentiment

File numbers found in text: 333-141504

Date
June 19, 2007
Author
THE BLACKSTONE GROUP L.P.
Form
CORRESP
Company
Blackstone Inc.

Letter

Re:

[Simpson Thacher & Bartlett LLP Letterhead]

VIA FACSIMILE AND EDGAR

June 19, 2007

Acceleration Request for The Blackstone Group L.P.

Registration Statement on Form S-1 (File No. 333-141504)

SECURITIES AND EXCHANGE COMMISSION

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

Attention: Pamela A. Long, Esq.

Ladies and Gentlemen:

Pursuant to Rule 461 under the Securities Act of 1933, as amended, we attach the requests of our client, The Blackstone Group L.P., and of the underwriters that effectiveness of the above-referenced Registration Statement be accelerated to 1:00 p.m., Washington D.C. time, on Thursday, June 21, 2007, or as soon as practicable thereafter. In addition, we hereby withdraw the requests previously submitted to the Commission that effectiveness of such Registration Statement be accelerated to 1:00 p.m., Washington D.C. time, on Wednesday, June 20, 2007. We ask, however, that the Commission staff not accelerate such effectiveness until we speak with you on June 21, 2007.

Please call me (212-455-3986) with any questions.

Very truly yours,

/s/ Joshua Ford Bonnie

Joshua Ford Bonnie

June 19, 2007

VIA FACSIMILE AND EDGAR

Re:

The Blackstone Group L.P.

Registration Statement on Form S-1

File No.: 333-141504

SECURITIES AND EXCHANGE COMMISSION

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

Ladies and Gentlemen:

Pursuant to Rule 461 under the Securities Act of 1933, as amended, The Blackstone Group L.P. (the “Partnership”) hereby requests that the effective date of the above-referenced Registration Statement be accelerated so that it may become effective at 1:00 p.m., Washington, D.C. time, on June 21, 2007, or as soon as possible thereafter. In this regard, the Partnership is aware of its obligations under the Securities Act.

The Partnership acknowledges that:

· should the Securities and Exchange Commission (the “Commission”) or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing;

· the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Partnership from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and

· the Partnership may not assert staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

Very truly yours,
THE BLACKSTONE GROUP L.P.

Show Raw Text
CORRESP
1
filename1.htm

[Simpson Thacher &
Bartlett LLP Letterhead]

VIA FACSIMILE AND EDGAR

June 19, 2007

  Re:

  Acceleration Request for The Blackstone Group L.P.

  Registration Statement on Form S-1 (File No.
  333-141504)

SECURITIES
AND EXCHANGE COMMISSION

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

Attention: Pamela A. Long, Esq.

Ladies and Gentlemen:

Pursuant
to Rule 461 under the Securities Act of 1933, as amended, we attach the
requests of our client, The Blackstone Group L.P., and of the underwriters that
effectiveness of the above-referenced Registration Statement be accelerated to
1:00 p.m., Washington D.C. time, on Thursday, June 21, 2007, or as soon as
practicable thereafter. In addition, we hereby withdraw the requests previously
submitted to the Commission that effectiveness of such Registration Statement
be accelerated to 1:00 p.m., Washington D.C. time, on Wednesday,
June 20, 2007.  We ask, however, that the Commission staff not
accelerate such effectiveness until we speak with you on June 21, 2007.

Please
call me (212-455-3986) with any questions.

  Very truly yours,

  /s/ Joshua
  Ford Bonnie

  Joshua Ford Bonnie

June 19, 2007

VIA FACSIMILE AND EDGAR

  Re:

  The Blackstone Group L.P.

  Registration Statement on Form S-1

  File No.: 333-141504

SECURITIES AND EXCHANGE
COMMISSION

Division of
Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

Ladies and Gentlemen:

Pursuant to Rule
461 under the Securities Act of 1933, as amended, The Blackstone Group L.P.
(the “Partnership”) hereby requests that the effective date of the
above-referenced Registration Statement be accelerated so that it may become
effective at 1:00 p.m., Washington, D.C. time, on June 21, 2007, or as soon as
possible thereafter.  In this regard, the
Partnership is aware of its obligations under the Securities Act.

The Partnership acknowledges that:

·                  should the
Securities and Exchange Commission (the “Commission”) or the staff, acting
pursuant to delegated authority, declare the filing effective, it does not
foreclose the Commission from taking any action with respect to the filing;

·                  the action of
the Commission or the staff, acting pursuant to delegated authority, in
declaring the filing effective, does not relieve the Partnership from its full
responsibility for the adequacy and accuracy of the disclosure in the filing;
and

·                  the Partnership
may not assert staff comments and the declaration of effectiveness as a defense
in any proceeding initiated by the Commission or any person under the federal
securities laws of the United States.

  Very truly yours,

  THE BLACKSTONE GROUP L.P.

  By:

  Blackstone Group Management L.L.C.,

  its general partner

  By:

  /s/ Robert L.
  Friedman

  Name: Robert L. Friedman

  Title: Chief Legal Officer

June
19, 2007

Securities
and Exchange Commission

100 F Street, N.E.
 Washington, D.C. 20549

  Re:

  The Blackstone Group L.P.

  Registration Statement on Form S-1

  Registration No. 333-141504

Ladies
and Gentlemen:

Pursuant
to Rule 461 under the Securities Act of 1933, as amended, the undersigned
hereby join in the request of The Blackstone Group L.P. that the effective date
of the Registration Statement be accelerated so that the Registration Statement
will be declared effective at 1:00 p.m. on Thursday, June 21, 2007, or as soon
thereafter as practicable.

In
connection with the Preliminary Prospectus distribution for the above-mentioned
issue, the prospective underwriters have confirmed that they are complying with
the requirements of Rule 15c2-8 under the Securities Exchange Act of 1934, as
amended.

The
following information with respect to the distribution of the Preliminary
Prospectus dated June 11, 2007 is furnished pursuant to Rule 460 of the Rules
and Regulations of the Commission under the Securities Act of 1933, as amended,
in connection with the request for acceleration of the effective date of the
Registration Statement.

The
undersigned have effected approximately the following distribution of copies of
the Preliminary Prospectus, dated June 11 2007:

  Number of Copies Dated June 11, 2007:

  To Prospective
  Underwriters

  55,642

  To Institutions

  0

  To Others (i.e.
  companies providing deal statistics)

  0

  Total

  55,642

  Yours truly,

  MORGAN STANLEY & CO. INCORPORATED

  CITIGROUP GLOBAL MARKETS INC.

  As Representatives to the Several Underwriters

  By: Morgan Stanley & Co. Incorporated

  By:

  /s/ Kenneth G. Pott

  Name: Kenneth G. Pott

  Title: Managing Director

  By: Citgroup Global Markets Inc.

  By:

  /s/ Michael Quadrino

  Name: Michael Quadrino

  Title: Vice President