Drinker Biddle & Reath LLP
One Logan Square
Suite 2000
Philadelphia, PA 19103-6996
(215) 988-2700 (Phone)
(215) 988-2757 (Facsimile)
www.drinkerbiddle.com
July 25, 2017
VIA EDGAR TRANSMISSION
Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549
Attn: Ms. Deborah O’Neal-Johnson
| Re: | Infinity Core Alternative Fund (the “Registrant”) |
(1933 Act Registration No. 333-217337)/(1940 Act Registration No. 811-22923)
Ladies and Gentlemen:
Enclosed is a request of the Registrant and its principal underwriter for acceleration of Pre-Effective Amendment No. 1 to the Registrant’s Registration Statement on Form N-2 under the Securities Act of 1933, as amended, and of Amendment No. 10 to the Registrant’s Registration Statement on Form N-2 under the Investment Company Act of 1940, as amended. Please contact me at (215) 988-3307 with any questions related to this request and to notify of the effectiveness of the Registration Statement. In my absence, please contact Joshua B. Deringer, Esq., at (215) 988-2959.
Sincerely,
/s/ Jillian L. Bosmann
Jillian L. Bosmann
Enclosure
