May 18, 2012
CONFIDENTIAL SUBMISSION VIA EMAIL
Draft Registration Statement | Confidential Submission | |
U.S. Securities and Exchange Commission | Pursuant to | |
100 F Street, NE | Title I, Section 106 under the | |
Washington, DC 20549 | Jumpstart Our Business Startups Act | |
and Section 24(b)(2) of the | ||
Securities Exchange Act of 1934 |
Re: | Confidential Submission of TriLinc Global Impact Fund, LLC’s Registration Statement on Form S-1 |
Ladies and Gentlemen:
On behalf of our client TriLinc Global Impact Fund, LLC, a Delaware limited liability company (the “Company”), we hereby confidentially submit a Registration Statement on Form S-1 (the “Registration Statement”) of the Company pursuant to Title I, Section 106 under the Jumpstart Our Business Startups Act (the “Jobs Act”) and Section 24(b)(2) of the Securities Exchange Act of 1934 for non-public review by the Staff of the Securities and Exchange Commission (the “Commission”) prior to the public filing of the Registration Statement. A copy of the Registration Statement is enclosed via this email submission.
Pursuant to Title 1, Section 101 of the Jobs Act, the Company is an “emerging growth company” that had total annual gross revenues of less than $1,000,000,000 during its most recently completed fiscal year ended December 31, 2011. Therefore, the Company is permitted to make this confidential submission of the Registration Statement for review by the Staff, provided that the Registration Statement and all amendments thereto shall be publicly filed with the Commission not later than 21 days before the date on which the Company conducts a road show, as such term is defined in Title 17, Section 230.433(h)(4) of the Code of Federal Regulations.
Please direct all notices and communications with respect to this confidential submission to each of the following:
Gloria Nelund, Chairman and Chief Executive Officer | ||
TriLinc Global Impact Fund, LLC | ||
1230 Rosecrans Ave, Suite 605,. | ||
Manhattan Beach, California 90266 | ||
Telephone: (310)997-0580 | ||
with copies to: | Judith D. Fryer, Esq. | |
Greenberg Traurig, LLP | ||
MetLife Building | ||
200 Park Avenue | ||
New York, New York 10166 | ||
Telephone: (212) 801-9200 | ||
Facsimile: (212) 801-6400 | ||
Lauren Prevost, Esq. | ||
Heath D. Linsky, Esq. | ||
Morris, Manning and Martin, LLP | ||
1600 Atlanta Financial Center | ||
3343 Peachtree Road, NE | ||
Atlanta, GA 30326, USA | ||
Phone: (404)233-7000 | ||
Fax: (404) 365-9532 |
If you have any questions with respect to this confidential submission, please call me at 212-801-6928 or Judith Fryer at 212-801-9330.
Very truly yours, |
/s/ Yuta N. Delarck, Esq. |
Yuta N. Delarck, Esq. |
Enclosures
cc: | Judith D. Fryer, Esq. |
Gloria S. Nelund, Chairman and Chief Executive Officer of the Company