LAW OFFICES OF
DERENTHAL & DANNHAUSER LLP
1999 HARRISON STREET, 26th Floor
OAKLAND, CALIFORNIA 94612
(510) 350-3070
FACSIMILE: (510) 834-8309
November 10, 2015
BY EDGAR
Ms. Pamela A. Long
Assistant Director
Division of Corporation Finance – Mail Stop 4631
Securities and Exchange Commission
100 F Street, NE
Washington, D.C. 20549
| Re: | ATEL 17, LLC (the “Company”) | |
| Registration Statement on Form S-1 | ||
| Filed May 4, 2015 | ||
| File No. 333-203841 |
Dear Ms. Long:
Concurrently with this letter, we are filing pre-effective amendment no. 2 to the above referenced registration statement.
In a prior letter dated October 27, 2015, we provided a supplemental response to the one outstanding comment in your letter of October 14, 2015, addressed to Dean Cash, concerning the above referenced filing, with the intention of addressing that comment in a final prospectus. As discussed with the staff by telephone, the Company has proceeded to file pre-effective amendment no. 2 to update unaudited interim financial statements and prior performance information. Consequently, we revise our supplemental response to the comment in your October 14 letter, as set forth below.
Note 2 – Basis of Presentation and Significant Accounting Policies, page F-10
| 1. | Please revise to disclose the specific day in September that you evaluated subsequent events through. Refer to ASC 855-10-50-1 for guidance. |
The Company includes in pre-effective amendment no. 2 unaudited interim balance sheet information for the Manager as of September 30, 2015, including updated footnotes to the balance sheet. The updated footnotes include a specific reference to the date through which subsequent events have been evaluated, November 10, 2015. See page F-11.
Ms. Pamela A. Long
November 10, 2015
Page 2
In addition to updated unaudited interim financial information for the Manager, the amendment includes updated unaudited interim financial statements for the Company, updated sponsor track record information and other disclosure updates. The amendment also includes as exhibits to the registration statement updated consents of the auditors to the inclusion of their reports on the Company’s audited financial statements and the Manager’s audited balance sheet.
We would hope to have leave to request acceleration of effectiveness of the registration statement as soon as may be practicable, and look forward to the staff advising us when it has had the opportunity to review the amendment and clear the Company to request acceleration.
Please contact the undersigned with any questions or comments concerning this filing.
| Very truly yours, | |
| /s/ Paul J. Derenthal | |
| Paul J. Derenthal |
| cc: | Tracey McKoy, Staff Accountant |
| Sherry Haywood, Staff Attorney | |
| Division of Corporation Finance | |
| Securities and Exchange Commission | |
| Mr. Dean L. Cash | |
| Mr. Paritosh Choksi | |
| Mr. Samuel Schussler | |
| Vasco Morais, Esq. |
