Mail Stop 3233 October 18, 2018 Via E-mail Wilbur Paes Chief Financial Officer Paramount Group, Inc. 1633 Broadway Suite 1801 New York, NY 10019 Re: Paramount Group, Inc. Form 10-K for the Fiscal Year Ended December 31, 2017 Filed February 15, 2018 File No. 001-36746 Dear Mr. Paes: We have completed our review of your filing. 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. Sincerely, /s/ Jennifer Monick Jennifer Monick Assistant Chief Accountant Office of Real Estate & Commodities