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                             May 31, 2022

       Brian J. McDade
       Chief Financial Officer
       Simon Property Group, Inc.
       225 West Washington Street
       Indianapolis, IN 46204

                                                        Re: Simon Property
Group, Inc.
                                                            Simon Property
Group, L.P.
                                                            Form 10-K for
fiscal year ended December 31, 2021
                                                            Filed February 24,
2022
                                                            File Nos. 001-14469
and 001-36110

       Dear Mr. McDade:

              We have limited our review of your filing to the financial
statements and related
       disclosures and have the following comments. In some of our comments, we
may ask you to
       provide us with information so we may better understand your disclosure.

              Please respond to these comments within ten business days by
providing the requested
       information or advise us as soon as possible when you will respond. If
you do not believe our
       comments apply to your facts and circumstances, please tell us why in
your response.

                                                        After reviewing your
response to these comments, we may have additional comments.

       Form 10-K for fiscal year ended December 31, 2021

       Item 7. Management's Discussion and Analysis of Financial Condition and
Results of Operations
       Non-GAAP Financial Measures, page 74

   1.                                                   We note your
calculation of the non-GAAP financial measures Beneficial interest of
                                                        Combined NOI and
Portfolio NOI. Please address the following:
                                                            Regarding your
calculation of Beneficial interest of Combined NOI, tell us and
                                                           clarify in future
filings whether the $431 million NOI from TRG and $743 million
                                                           NOI from Other
Platform Investments and Investments represents is the entirety of
                                                           such entities' NOI,
or if such amounts represent your share of NOI based on your
                                                           non-controlling
interests in such entities, and the basis for including such amounts.
                                                           Additionally clarify
the unconsolidated entities included in "Other Platform
                                                           Investments and
Investments" line item;
                                                            Regarding Portfolio
NOI, expand on the usefulness of such measure, given your
 Brian J. McDade
Simon Property Group, Inc.
May 31, 2022
Page 2
              indication it is used to measure the operating performance of
your portfolio yet does
              not appear to adequately address the additions and deductions
used to calculate such
              measure; and
                Additionally, tell us why you believe the presentation of the
subtotal Beneficial
              interest of Combined NOI provides useful information to investors
given that
              such measure includes NOI from certain sources that almost in
their entirety, appear
              to be subsequently deducted to calculate your measure of
Portfolio NOI. In your
              response, tell us why you have deducted your share of NOI of
Klepierre, and not that
              of third-party investors, in calculating Portfolio NOI.
Item 8. Financial Statements
Consolidated Statements of Cash Flows, page 89

2.       Please tell us and disclose in future periodic filings non-cash
investing and financing
         activities conducted during the periods presented. Refer to ASC
230-10-50-3.
Note 6. Investments in Unconsolidated Entities and International Investments
Summary Financial Information, page 115

3.       We note that the summary financial information of your equity method
investments on
         pages 116-118 excludes your investments in Klepierre, TRG and other
platform
         investments. Please tell us why you believe it is more beneficial to
investors to provide a
         narrative description of the financial information of Klepierre and
TRG when the financial
         information of other equity method investments has been presented in a
tabular format.
         Also tell us why you believe the exclusion of your other platform
investments from the
         summary financial information is compliant with Rule 4-08(g) of
Regulation S-X.
       In closing, 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.

      You may contact Mark Rakip at (202) 551-3573 or Kristi Marrone at (202)
551-
3429 with any questions.



FirstName LastNameBrian J. McDade                              Sincerely,
Comapany NameSimon Property Group, Inc.
                                                               Division of
Corporation Finance
May 31, 2022 Page 2                                            Office of Real
Estate & Construction
FirstName LastName