April 5, 2019

Mark M. Hedstrom
Chief Financial Officer
Colony Capital, Inc.
515 South Flower Street
44th Floor
Los Angeles, CA 90071

       Re: Colony Capital, Inc.
           Form 10-K for the year ended December 31, 2018
           Filed March 1, 2019
           File No. 001-37980

Dear Mr. Hedstrom:

       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 the year ended December 31, 2018

Item 7. Management's Discussion and Analysis of Financial Condition and Results
of Operations
NOI and EBITDA, page 80

1.    We note your calculation of EBITDA contains adjustments for items other
than interest,
      taxes, depreciation and amortization. Please revise in future filings to
ensure that
      measures calculated differently from EBITDA are not characterized as
EBITDA. See
      Question 103.01 of the updated Compliance and Disclosure Interpretations
issued on May
      17, 2016. This comment also applies to your characterization of EBITDA
within your
      earnings release.
 Mark M. Hedstrom
Colony Capital, Inc.
April 5, 2019
Page 2
Notes to Consolidated Financial Statements
2. Summary of Significant Accounting Policies
Business Combinations, page F-15

2.       We note your disclosure that no gain or loss is recognized for asset
acquisitions unless the
         fair value of non-cash assets given as consideration differs from the
carrying amount of
         the assets acquired. Please clarify this disclosure for us; in this
regard, please address how
         you determined the carrying amount of the assets acquired in these
transactions.
       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 Isaac Esquivel, Staff Accountant, at (202) 551-3395 or
Jennifer
Monick, Assistant Chief Accountant, at (202) 551-3295 with any questions.



                                                                Sincerely,
FirstName LastNameMark M. Hedstrom
                                                                Division of
Corporation Finance
Comapany NameColony Capital, Inc.
                                                                Office of Real
Estate and
April 5, 2019 Page 2                                            Commodities
FirstName LastName