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CORRESP
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S.E.C Correspondence Letter

 December 5, 2008

 VIA
COURIER AND EDGAR

 RE:   The Blackstone Group L.P.

 Form 10-K for Fiscal Year Ended

 December 31, 2007; Forms 10-Q for Fiscal

 Quarters Ended March 31, 2008 and

 June 30, 2008

 File No. 1-33551

 Mr. Rufus Decker

 Securities and Exchange Commission

 Division of Corporation Finance

 100 F Street, N.E.

 Mailstop 7010

 Washington, D.C. 20549

 Dear Mr. Decker:

 On
behalf of The Blackstone Group L.P., we are responding to your comment letter, dated October 31, 2008, regarding our Form 10-K for Fiscal Year Ended December 31, 2007 and Forms 10-Q for Fiscal Quarters Ended March 31, 2008 and
June 30, 3008.

 To assist your review, we have retyped the text of the Staff’s comments in italics below. Please note that references to page
numbers in our responses refer to the page numbers of our EDGAR-filed Form 10-K or Form 10-Q, as applicable.

 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 included in your future filings, including your interim filings.

 Where appropriate, we have provided
as part of our responses below proposed additional disclosures or other revisions to be made in our future periodic filings, including our future interim filings.

The Blackstone Group® L.P.

345 Park Avenue

New York, NY 10154

212 583-5000

 Mr. Rufus Decker

 December 5, 2008

 Page 2 of 29

 Legislation has been introduced that would, if enacted, preclude us..., page 17

2.
Please tell us, with a view toward future disclosure, the status of the legislation discussed in this risk factor. We also note the disclosure under “Income Taxes” on
page 58.

 The status of this proposed legislation is unchanged from what we have disclosed in the risk factor and MD&A
disclosures identified by the Staff. We carefully monitor the status of this proposed legislation and will update our disclosures as appropriate in our future filings.

 Management’s Discussion and Analysis of Financial Condition and Results of Operations, page 53

 General

3.
Throughout your MD&A, you discuss the change in your Assets Under Management compared to the prior period. In future filings, please provide a reconciliation of Assets Under
Management that shows the activity between the beginning balance and the ending balance. Please separately disclose and discuss inflows and redemptions on a gross basis such that readers can clearly identify any trends depicted by these inflows and
outflows.

 We will expand our disclosures in our 2008 Annual Report on Form 10-K and subsequent quarterly filings on Form
10-Q to disclose the activity between the beginning and ending balance of assets under management with added disclosure, as necessary, to discuss significant fluctuations between the periods presented. Please refer to Exhibit A to this letter for
the format of the proposed disclosures.

4.
You disclose on page 21 that poor performance of your investment funds would cause a decline in your revenue, income and cash flow and could adversely affect your ability to
raise capital. In order to help investors better understand how fund performance affects your financial statements, please revise to provide performance information for each of your funds for each period presented. Fund performance information
should include the name of the fund, inception date, assets under management as of each period presented, net annualized return since inception and net return for each period presented.

 We do not believe that disclosure of detailed performance information within MD&A for each of the investment funds that we manage for each period
presented is either required by Regulation S-K or, more importantly, a meaningful measurement of our results of operations. The principal disclosure to reflect our revenue recognition of performance fees is the disclosure of changes to performance
fees and investment income set forth in our segment disclosure in MD&A and the financial statements. The individual rates of return have no direct impact on our financials and therefore we question the relevance to our investors. The relevant
information for investors is the enhanced disclosure regarding the changes in our assets under management which we disclose in our Annual Report on Form 10-K and Quarterly Reports on Form 10-Q and which we propose to expand in future filings as
described above and in Exhibit A attached hereto.

 Mr. Rufus Decker

 December 5, 2008

 Page 3 of 29

 Consolidation and Deconsolidation of Blackstone Funds, page 55

5.
Please revise your filing to more clearly indicate which funds were de-consolidated as of December 31, 2007 and which funds remain consolidated as of December 31, 2007.
Please also revise your MD&A to explain in greater detail how the de-consolidation of funds impacted your balance sheet and results of operations. It is unclear how much of the fluctuations in your financial statements are attributable to the
de-consolidation of funds as opposed to other operational factors. Please consider presenting the assets and liabilities of your consolidated funds separate from the assets and liabilities attributable to your operations on the face of your balance
sheet.

 We propose to include a supplemental item in future filings presenting the Blackstone operating partnerships
separate from the consolidated funds formatted as set forth in Exhibit B to this letter. This disclosure also includes an identification of the consolidated funds.

 Liquidity and Capital Resources, page 71

6.
We note your disclosure on page 118 that you were in compliance with all loan covenants as of December 31, 2007. In light of the current credit environment, please revise
your filing here and in your financial statement footnotes to disclose your material financial debt covenant computations for each period presented, along with a reconciliation to relevant GAAP amounts, as applicable. Your disclosure should indicate
both the covenant requirements and your computations demonstrating how you complied with the covenants for each period presented.

 Blackstone currently has no net debt outstanding (nor do we foresee our incurring net debt in the near future) because our business generally does not require debt at the corporate level. We have a significant cash position in excess of the
amount of our short-term borrowings under our revolving credit facility. Consequently, we do not believe that it would provide meaningful disclosure to our investors to present detailed computations regarding our covenant compliance.

 Critical Accounting Policies, page 76

 General

7.
We note some of your material revenue streams are based on the value of Assets Under Management (AUM). Please disclose how you calculate the value of your assets under
management. If significant judgment is involved in the calculation of AUM and this

 Mr. Rufus Decker

 December 5, 2008

 Page 4 of 29

 directly impacts such calculation of your revenue recognition, please tell us how you considered the need to identify AUM as a critical accounting policy. We believe the following disclosures would be useful to investors:

•

 Explanation of each of the models/techniques used to estimate fair value of the underlying Assets Under Management;

•

 Detailed discussion of the material estimates and assumptions used in each of the models; and

•

 Sensitivity analysis of the material estimates and assumptions for each of the models used on the fair value of the Assets Under Management.

 Please refer to Section 501.14 of the Financial Reporting Codification for guidance.

 Assets under management is not a critical accounting policy but rather a key operating metric. For example, management fees on the carry funds are based
on committed capital during the investment period and not the fair value of assets under management.

 As noted in our response to comment 3,
we will prospectively provide enhanced disclosure regarding assets under management. Additionally, there are hundreds, if not thousands, of models used across our assets for the determination of fair value, and we do not believe that disclosure of
these models will meaningfully enhance the understanding of our financials.

 Investments, at Fair Value, page 77

8.
With regards to all of your Level 3 investments, please revise your MD&A to provide the following information, to the extent material:

•

 detailed discussion of how realized gains (losses) affected your results of operations, liquidity or capital resources during the period presented, if
applicable. Specifically address how realized and unrealized gains (losses) impacted performance fees and allocations (carried interest) and other revenue line items. Please also disclose how much of your carried interest was generated from realized
versus unrealized gains;

•

 explanation for any material decline or increase in fair values; and

•

 whether the fair values diverge materially from the amounts you currently anticipate realizing on settlement or maturity. If fair values diverge from
expectations, please disclose why and provide the basis for your views.

 We agree with the Staff’s comment
regarding the effect realized gains (losses) has on our results of operations and liquidity and capital resources. In fact, we had already expanded our disclosures in the Liquidity and Capital Resources section of our September 30, 2008 Form
10-Q to provide more information in this regard. Specifically, we refer the Staff to Part I. Item 2. Management’s Discussion and Analysis of Financial Condition and Results of Operations, Liquidity and Capital Resources, pages 50-55.
Included within our revised Liquidity and Capital Resources discussion is a table which specifically identifies the amount of performance fees and allocations from realized gains. Please see the item “Performance Fees and Allocations Net of
Related Compensation” in the table at the top of page 52. For the Staff’s convenience, a copy of these disclosures has been provided at Exhibit C.

 Mr. Rufus Decker

 December 5, 2008

 Page 5 of 29

 We agree with the Staff’s comment to address how realized and unrealized gains (losses) affect our performance fees and allocations and we will provide enhanced disclosure in our upcoming filings. Specifically, we will revise the
following paragraph in our September 30, 2008 Form 10-Q which is in Part I. Item 2. Management’s Discussion and Analysis of Financial Condition and Results of Operations, Critical Accounting Policies, Revenue Recognition, page 56. Our
proposed changes are highlighted.

 Performance Fees and Allocations. Performance fees and allocations represent the
preferential allocations of investment gains (“carried interest”) which are a component of our general partner interests in the corporate private equity, real estate and debt funds. We are entitled to carried interest from an investment
fund in the event investors in the fund achieve cumulative investment returns in excess of a specified rate. We record as revenue the amount that would be due to us pursuant to the fund agreements at each period end as if the fair value of the
investments were realized as of such date whether or not such amounts have actually been realized. In certain performance fee arrangements related to funds of hedge funds and hedge funds in our Marketable Alternative Asset Management segment,
we are entitled to receive performance fees and allocations when the return on assets under management exceeds certain benchmark returns or other performance targets. In such arrangements, performance fees and allocations are accrued monthly or
quarterly based on measuring account / fund performance to date (whether or not such amounts have actually been realized) versus the performance benchmark stated in the investment management agreement.

 With respect to the Staff’s request for us to provide an explanation of any material decline or increase in fair values and whether the fair values
of our investments may diverge materially from the amounts we currently anticipate realizing on settlement or maturity, we propose to include additional disclosure along the following lines in the MD&A section in our upcoming 2008 Annual Report
on Form 10-K to the extent there has been such a material decline. (The actual disclosure will of course depend upon the facts and circumstances then existing.)

 Investments within the Level III category have experienced significant net declines in their fair values of $xx.x million as of
December 31, 2008 as compared to December 31, 2007. The main causes of the reduction in their fair values were the declines in global equity and debt markets, lower operating projections for some portfolio companies and an increase in
capitalization rates for some real estate investments to reflect a softening economy and adverse fluctuations in foreign exchange rates during the year ended December 31, 2008. We believe these estimated fair value amounts should be utilized
with caution as we have no current intention to dispose of any of these investments. Our intent is to hold investments and securities until prevailing market conditions are beneficial for investment sales.

 Mr. Rufus Decker

 December 5, 2008

 Page 6 of 29

9.
To the extent material to your own facts and circumstances, you may wish to consider the following additional fair value measurement disclosure items in your Management’s
Discussion and Analysis:

•

 The significant judgments you made in classifying a particular financial instrument in the fair value hierarchy;

•

 The criteria you used to determine whether the market for a financial instrument is active or inactive (i.e., illiquid); and

•

 Which financial instruments are affected by the lack of market liquidity (i.e. inactivity), how the lack of liquidity impacted the valuation technique you used,
and how you factored illiquidity into your fair value determination of those financial instruments. For example, to the extent you used a discounted cash flow approach to determine the fair value of a financial instrument, such as auction rate
securities, loans held for sale, or mortgage-backed securities backed by subprime or Alt-A collateral, consider discussing the specific change in the discount rate or any other analysis you performed to account for the lack of liquidity and discuss
how and why you changed your assumptions from prior periods.

 Blackstone’s investments predominantly encompass
two levels of the fair value hierarchy: Level I investments where quoted prices are available in active markets for identical investments as of the reporting date, and Level III investments where pricing inputs are unobservable for the investment
and include situations where there is little, if any, market activity for the investment. Investments that are included in Level III primarily include general and limited partnership interests in corporate private equity and real estate funds, funds
of hedge funds, and distressed debt vehicles.

 We believe our September 30, 2008 Form 10-Q disclosures, which have been enhanced from
the prior two quarterly 2008 filings on Form 10-Q, within Part I. Item 2. Management’s Discussion and Analysis of Financial Condition and Results of Operations, Critical Accounting Policies, Investments, at Fair Value, addresses the
material items of this comment. We will continue to make this enhanced disclosure in future filings. For the Staff’s convenience, a copy of these disclosures has been provided at Exhibit D.

10.
We note your disclosure on page 77 that futures and swap contracts may be valued based on prices obtained from recognized financial data service providers. If you use
brokers or pricing services to assist you in determining fair values, consider explaining the extent to whi