UNITED STATES
                                    SECURITIES AND EXCHANGE COMMISSION
                                                 WASHINGTON, D.C. 20549


     DI VISION OF
CORPORATI ON FI NANCE


                                                                  December 2,
2019

  By E-Mail

  David W. Bonser, Esq.
  Hogan Lovells
  555 Thirteenth Street NW
  Washington, DC 20004

           Re:     Colony Capital, Inc.
                   Soliciting Materials filed pursuant to Rule 14a-12
                   Filed on November 26, 2019
                   File No. 001-37980

  Dear Mr. Bonser:

        We have reviewed your filing 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 this letter by amending your filing, by providing
the requested
  information, or by advising us when you will provide the requested response.
If you do not
  believe our comments apply to your facts and circumstances or do not believe
an amendment is
  appropriate, please tell us why in your response.

         After reviewing any amendment to your filing and the information you
provide in
  response to these comments, we may have additional comments.

  Soliciting Materials

  1.       Each statement or assertion of opinion or belief must be clearly
characterized as such,
           and a reasonable factual basis must exist for each such opinion or
belief. Support for
           opinions or beliefs should be self-evident, disclosed in the proxy
statement or provided to
           the staff on a supplemental basis. Provide support for the following
statements:

                   That "the pivot to digital should also have a significantly
positive effect on the
                   Company's operating efficiency."

                   That "[t]here are a number of inaccuracies in Blackwells'
press release..."

  2.       Please ensure that you remove doubt expressed by your use of the
phrase "may be
           deemed" ("Important Additional Information") from whether the
company, its directors
           and officers are participants in the solicitation. See instruction 3
to Item 4 in Schedule
           14A.
 David W. Bonser, Esq.
Hogan Lovells
December 2, 2019
Page 2


      Please direct any questions to me at (202) 551-3619.

                                                             Sincerely,

                                                             /s/ Daniel F.
Duchovny
                                                             Daniel F. Duchovny
                                                             Special Counsel
                                                             Office of Mergers
and Acquisitions