TEXT-EXTRACT 2 filename2.txt May 22, 2019 Garett Rosenblum Chief Accounting Officer iStar Inc. 1114 Avenue of the Americas, 39th Floor New York, NY 10036 Re: iStar Inc. Form 10-K for the fiscal year ended December 31, 2018 Filed February 26, 2019 File No. 001-15371 Dear Mr. Rosenblum: We have reviewed your May 6, 2019 response to our comment letter and have the following comment. In our comment, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this comment 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 comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this comment, we may have additional comments. Unless we note otherwise, our references to prior comments are to comments in our April 11, 2019 letter. FORM 10-K FOR THE YEAR ENDED DECEMBER 31, 2018 Item 7. Management's Discussion and Analysis of Financial Condition and Results of Operations Adjusted Income, page 46 1. We have considered your response to comment one. Given that your adjustment relates to gains on prior year transactions, we continue to be unclear how adjusting for such gains provides an accurate reflection of your 2018 operating performance. Please advise or revise future filings accordingly. You may contact Wilson K. Lee, Senior Staff Accountant, at (202) 551 - 3468 or Jennifer Monick, Assistant Chief Accountant, at (202) 551 - 3295 with any questions. Garett Rosenblum iStar Inc. May 22, 2019 Page 2 Sincerely, FirstName LastNameGarett Rosenblum Division of Corporation Finance Comapany NameiStar Inc. Office of Real Estate and May 22, 2019 Page 2 Commodities FirstName LastName