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                                                           June 1, 2018



Martin A. Kropelnicki
Chief Executive Officer
California Water Service Group
1720 North First Street
San Jose, CA, 95112

       Re:    SJW Group
              DFAN14A filed June 1, 2018
              Filed by California Water Service Group
              File No. 001-08966

Dear Mr. Kropelnicki:

       We have reviewed the filing listed above and have the following comment.
Please
respond to this comment promptly. If you do not believe our comment applies to
your facts and
circumstances, please tell us why in your response. After reviewing your
response, we may have
additional comments.

   1. Your disclosures appear to present your offer as a transaction that is
currently being
      presented to SJW shareholders, rather than merely a proposal. For
example, you assert to
      SJW shareholders that "California Water is offering you significant and
immediate
      value." However, SJW shareholders are not voting to approve your proposal
nor is it
      certain that an actual transaction for you to acquire SJW will ever be
presented to them,
      either for a vote or as a tender offer. Please refrain from
characterizing your proposal as
      an existing transaction, considering your proposal is non-binding and
subject to numerous
      regulatory approvals. We note that we raised this issue with you
previously in prior
      comments dated May 11, 2018 where we asked that your refrain from
implying in future
      solicitations that your offer is certain, which you acknowledged in a
response letter dated
      May 15, 2018. Therefore, please tell us what steps you will take at this
time to correct
      these statements.
 Martin A. Kropelnicki
California Water Service Group
June 1, 2018
Page 2



        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. Please contact Katherine Bagley, Staff Attorney, at (202)
551-2545, Mara
Ransom, Assistant Director, Office of Consumer Products, at (202) 551-3720, or
me at (202)
551- 3263 with any other questions.



                                                          Sincerely,


                                                          /s/ Christina Chalk


                                                          Christina Chalk
                                                          Senior Special
Counsel
                                                          Office of Mergers and
Acquisitions




cc:    Eduardo Gallardo, Esq. (via email)
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