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| CLIFFORD CHANCE US LLP 31 West 52nd Street New York, NY 10019-6131 Tel +1 212 878 8000 Fax +1 212 878 8375 www.cliffordchance.com |
September 30, 2016
VIA EDGAR
Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Re: | CNL Strategic Capital, LLC |
Registration Statement on Form S-1 |
Ladies and Gentlemen:
On behalf of CNL Strategic Capital, LLC (the "Company"), we hereby confidentially submit a draft Registration Statement on Form S-1 (the "Registration Statement") pursuant to Section 6(e) of the Securities Act of 1933, as amended (the "Securities Act"), for non-public review by the Staff of the Securities and Exchange Commission prior to the public filing of the Registration Statement. The Registration Statement relates to the Company's proposed offering of shares of its limited liability company interests. The Company qualifies as an "emerging growth company" within the meaning of Section 6(e) of the Securities Act.
Please do not hesitate to contact me at (212) 878-8324 with any questions you may have regarding this confidential submission.
Sincerely, | |
/s/ Jason D. Myers | |
Jason D. Myers |
cc: | CNL Strategic Capital, LLC |
Kirk A. Montgomery | |
Clifford Chance US LLP | |
Jay L. Bernstein |