United States securities and exchange commission logo 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.