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Correspondence

 June 25, 2012

 VIA COURIER AND EDGAR

RE:

The Blackstone Group L.P.

 Form 10-K for the Year Ended

December 31, 2011

Form 10-Q for the Period Ended

March 31, 2012

File No. 1-33551

 Mr. Rufus Decker

 Accounting Branch Chief

 Securities and Exchange Commission

Division of Corporation Finance

 100 F Street,
N.E.

 Washington, D.C. 20549

 Dear
Mr. Decker:

 On behalf of The Blackstone Group L.P. (“Blackstone”), we are responding to your comment letter dated
June 11, 2012 regarding our Form 10-K for the Year Ended December 31, 2011 and our Form 10-Q for the Period Ended March 31, 2012.

 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
December 31, 2011 Annual Report on Form 10-K (“2011 Form 10-K”) and the March 31, 2012 Quarterly Report on Form 10-Q (“March 31, 2012 Form 10-Q”).

FORM 10-K FOR THE YEAR ENDED DECEMBER 31, 2011

 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, if applicable.

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

 June 25, 2012

  Page
 2
 of 12

 Item 1. Business

 Capital Invested In and Alongside Our Investment Funds, page 14

2.
We note your response to comment two in our letter dated May 3, 2012. Please address the following:

•

 Please help us better understand the nature of side-by-side entities and how they relate to your side-by-side investments;

•

 Your response indicates that you do not consolidate any entities that hold co-investments whereas interests in entities that hold side-by-side
investments may be consolidated. Please help us understand the differences between these two types of entities and correspondingly why one would never be consolidated and other may be consolidated;

•

 Please help us better understand how significant these co-investment and side-by-side investment entities are by providing us with summarized
financial information related to each of these types of entities. Please provide us with a further breakdown for side-by-side investment entities to separately show financial information for those entities that you do and do not consolidate. The
summary financial information should include total assets, total liabilities, total revenues, total expenses, and the total net income of these entities; and

•

 In your description of Assets Under Management throughout the filing, including on page 2, you refer to co-investments. Please help us understand
why side-by-side investments would not also be included in your determination of Assets Under Management.

Side-by-side (“SBS”) entities refer to entities established for purposes of facilitating investments by Blackstone affiliated
individuals. Generally, these entities will invest in the same portfolio companies as a carry fund established for third party investors. We refer to the co-investments made by a SBS entity as SBS investments.

Co-investment opportunities are sometimes made available to third party investors to allow them to make an investment in a particular
asset alongside one of the firm’s funds. Entities through which these co-investments by third parties are facilitated are referred to as “Co-Investments”.

 SBS investments and Co-Investments apply to two completely distinct sets of investors.

 As discussed in our May 17, 2012 response to comment 2, Co-Investment entities which are held by third party investors generally are not subject to consolidation as Blackstone is not the primary
beneficiary according to the guidance under ASC 810-10 or Blackstone, as general partner of these entities, does not control the Co-Investment entity according to the guidance under ASC 810-20.

With respect to SBS investments and their related entities, for certain non-partner employee investors in these entities, Blackstone
provides financing to facilitate their SBS investments. We evaluate whether this implicit financial interest results in Blackstone being identified as the primary beneficiary under ASC 810-10 and therefore required to consolidate such entities.
Where financing is not provided by Blackstone, we have determined that Blackstone is not the primary beneficiary and therefore is not required to consolidate such entities.

 Mr. Rufus Decker

 June 25, 2012

  Page
 3
 of 12

 The number of entities and the respective summary financial information as of and for
the year ended December 31, 2011 for each entity type is presented below.

Non-Consolidated Entities

Consolidated
Entities (a)

Co-
Investment

SBS

SBS

(Dollars in Millions, Except Number of Entities)

 Number of Entities

21

23

68

 Total Assets

$
6,159.3

$
725.2

$
839.7

 Total Liabilities

$
17.7

$
9.3

$
38.1

 Total Revenues

$
537.8

$
30.9

$
154.9

 Total Expenses

$
3.2

$
0.8

$
2.4

 Total Net Income

$
534.6

$
30.1

$
152.5

(a)
Amounts presented before intercompany eliminations.

 Please note that Blackstone holds no interest in the non-consolidated SBS entities and is not entitled to receive any management or performance-based fees. As a result, there are no amounts reflected in
the consolidated financial statements of Blackstone related to our relationship with these entities. With respect to Co-Investment entities, Blackstone may hold a minority equity interest (typically, up to 7%) and may be entitled to receive
management and performance-based fees. As a result, the amounts recognized in the consolidated financial statements are limited to our equity interest and any fees arising from managing such entities.

In response to the Staff’s request regarding SBS investments and our determination of Assets Under Management, SBS investments are
included in our determination of Assets Under Management. The following is an excerpt from our definition of Assets Under Management on page 2 of our March 31, 2012 Form 10-Q:

“…the fair value of the investments held by our carry funds plus the capital that we are entitled to call from investors in
those funds pursuant to the terms of their capital commitments to those funds plus the fair value of co-investments managed by us…”

 Mr. Rufus Decker

 June 25, 2012

  Page
 4
 of 12

 Our SBS investments are included in “our carry funds” and, as such, are
included in Assets Under Management as reported. In future filings, we will clarify this as follows (marked to show changes):

“…the fair value of the investments held by our carry funds and our side-by-side investments, plus the capital that we
are entitled to call from investors in those funds and side-by-side investments pursuant to the terms of their respective capital commitments to those funds, plus the fair value of co-investments managed by
us…”

 Management’s Discussion and Analysis, page 67

 Consolidated Results of Operations, page 77

3.
We note your response to comment four in our letter dated May 3, 2012. Please quantify the impact of each significant item that impacted your effective income
tax rate from period to period.

 We will provide an enhanced annual MD&A discussion for the significant
variances in the provision (benefit) for taxes and corresponding effective tax rate from period to period. The following is the disclosure we would have provided in the Consolidated Results of Operations section of our MD&A on page 79 of our
2011 Annual Report on Form 10-K:

 Provision for Taxes

Blackstone’s provision for taxes for the periods ended December 31, 2011, 2010 and 2009 was $345.7 million,
$84.7 million and $99.2 million, respectively, with an effective tax rate of 447.5%, -16.2% and -4.3%, respectively. Pre-tax book income was $77.3 million for 2011 compared with a pre-tax book loss of $522.7 million for 2010 and a pre-tax book loss
of $2.3 billion for 2009.

 Three factors contributed to the increase in the effective income tax rate of 447.5%
for 2011 compared to -16.2% for 2010. First, $233.7 million of deferred tax assets were reversed in 2011 due to a lower apportionment of income subject to New York State and New York City taxes. The lower apportionment of income to New York State
and New York City also resulted in an income tax benefit of $69.2 million for the exclusion of the $197.8 million book income realized from the reduction to the tax receivable agreement liability. The 2011 net effective income tax rate
resulting from the change in tax rates was 202.9%.

 Second, pre-tax book income (loss) includes pre-tax losses
of $169.7 million and $389.0 million for 2011 and 2010, respectively, that is passed through to common unitholders and non-controlling interests and is not taxable to the Partnership and its subsidiaries, which resulted in an effective tax rate
of 76.9% in 2011, the year with pre-tax book income, and an effective tax rate of -26.1% in 2010, the year with a pre-tax book loss.

 Third, the book equity-based compensation expense exceeds the tax deductible equity-based compensation expense due to the issuance of units that are not tax deductible since they represent a value for
value exchange for tax

 Mr. Rufus Decker

 June 25, 2012

  Page
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 of 12

purposes, which also increases the income tax provision by $102.3 million and the effective tax rate by 132.4% in 2011, the year with a pre-tax book income, and increases the income tax provision
by $132.1 million but reduces the effective rate by 25.3% in 2010, the year with a pre-tax book loss.

 All
factors except the reversal of the deferred tax asset are expected to impact the effective tax rate for future years.

 The increase in the 2010 effective tax rate compared with the prior year resulted from the lower amount of pre-tax book loss compared with the prior year pre-tax book loss amount.

Additional information regarding our income taxes can be found in Note 13. “Income Taxes” in the “Notes to
Consolidated Financial Statements” in “Part II. Item 8. Financial Statements and Supplementary Data” of this filing.

Other Income, page 79

4.
We note your response to comment five in our letter dated May 3, 2012. Please address the following:

•

 Please tell us the nature of the legal entity reorganization executed in 2011 and correspondingly why the reorganization resulted in you now needing
to apply the New York City and New York State sourcing rules. Please help us understand why these rules did not need to be applied prior to the reorganization;

•

 Please help us understand why the application of the rules resulted in you now using the address of the customer versus the location of the
individuals performing the services. Please clarify if the rules specify that you should use the address of the customer; and

•

 Please help us better understand how the application of the sourcing rules resulted in a lower effective tax rate and correspondingly a reduction in
the amounts due to non-controlling interest holders.

 During 2011, we executed a reorganization (as
referenced in our May 17, 2012 response to comment 5) whereby we consolidated commonly controlled advisor entities that are disregarded for U.S. tax purposes as subsidiaries of Blackstone Advisory Partners L.P., a commonly controlled entity
that is registered with the Securities and Exchange Commission and the Financial Industry Regulatory Authority as a broker-dealer. As subsidiaries of the broker-dealer entity that are disregarded for tax purposes, for New York State and New York
City tax return purposes they are deemed to be “divisions” of the broker-dealer entity and eligible to utilize the broker-dealer revenue sourcing rules. Prior to the reorganization, the revenue sourcing rules would have applied only to the
broker-dealer entity and their impact would have been immaterial to The Blackstone Group L.P. consolidated financial statements.

 Mr. Rufus Decker

 June 25, 2012

  Page
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 of 12

 It is well established that for entities that are not broker-dealers, gross receipts are
sourced where the services are performed. By contrast, New York City law provides that for broker-dealers, receipts for management or advisory services are sourced to New York City if the mailing address of the customer paying such fees is located
in New York City. Prior to the reorganization, the referenced advisor entities sourced their gross receipts based on where the services were performed. After the reorganization, gross receipts were sourced to the location of the customer. (N.Y.C.
Admin. Code Para. 11-508(c)(3)) (N.Y.C. Admin. Code Para. 11-508(e-3))

 A wholly-owned corporate subsidiary of The Blackstone
Group L.P. is the indirect general partner of the broker-dealer. This corporate subsidiary is subject to New York State and New York City corporate taxes. New York State law provides that for broker-dealers, receipts for management or advisory
services are sourced to New York if the mailing address of the customer paying such fees is located in New York. (N.Y. Tax Law Para. 210(3))

 For the advisor entities referenced above and, subsequently, for the corporate subsidiary that is the general partner, sourcing of receipts by customer location results in a lower amount of New York State
and New York City receipts than if sourced by the location of where the work is done. The lesser amount of gross receipts sourced to New York State and New York City results in a lower business allocation factor for the corporate subsidiary and a
reduction in its effective rate of tax since less income is apportioned to and taxed by New York State and New York City. This reduction applies to the period after the reorganization and to all future periods.

This correspondingly reduces the amount due to non-controlling interest holders under the tax receivable agreement because that liability
is determined by the amount of tax savings realized by the wholly-owned subsidiary from the future amortization of the intangibles resulting from the taxable purchases or exchanges of interests from certain current or former non-controlling interest
holders.

 Mr. Rufus Decker

 June 25, 2012

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 of 12

 Financial Statements

 Consolidated Statement of Changes in Partners’ Capital, page 133

5.
We note your response to comment nine in our letter dated May 3, 2012. It appears that the Appropriated Partners’ Capital column should also be included in
equity attributable to The Blackstone Group L.P. Please revise your presentation. See ASC 810-10-50-1A(c) and ASC 810-10-55-4L.

 We agree that Appropriated Partners’ Capital is also attributable to The Blackstone Group L.P. and will revise our presentation to reflect this.

Please see Exhibit A for the prospective presentation of our 2011 Consolidated Statement of Changes in Partners’ Capital, which would
have been included on page 135 of our 2011 Form 10-K.

6.
We note your response to comment 10 in our letter dated May 3, 2012. We continue to believe that the amounts reported under the non-controlling interests in
consolidated entities column for net income should agree to the amounts reported on your statements of operations. In addition, the sum of the net income (loss) and currency translation adjustment amounts reported in the non-controlling interests
columns should equal the amount of comprehensive income (loss) attributable to non-controlling interests presented on this statement. It appears that the amounts currently presented for net income (loss) and currency translation adjustment under the
appropriated partners’ capital column should be reflected instead under a non-controlling inter