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                 December 27, 2022

       Douglas B. Heitner
       Chief Legal Officer
       ISTAR INC.
       1114 Avenue of the Americas, 39th Floor
       New York, NY 10036

                                                        Re: ISTAR INC.
                                                            Registration 
Statement on Form S-4
                                                            Filed December 16, 
2022
                                                            File No. 333-268822

       Dear Douglas B. Heitner:

              This is to advise you that we have not reviewed and will not 
review your registration
       statement.

               Please refer to Rules 460 and 461 regarding requests for 
acceleration. We remind you
       that the company and its management are responsible for the accuracy and 
adequacy of their
       disclosures, notwithstanding any review, comments, action or absence of 
action by the staff.

             Please contact ictor Rivera Melendez at 202-551-4182 and Jeffrey 
Gabor at 202-551-
       2544 with any questions.



                                                                                
                 Sincerely,

                                                                                
                 Division of Corporation Finance
                                                                                
                 Office of Real Estate & Construction
       cc:                                              Kathleen L. Werner, 
Esq.