LAW OFFICES OF DERENTHAL & DANNHAUSER LLP ONE POST STREET, SUITE 575 SAN FRANCISCO, CALIFORNIA 94104 (415) 981-4844 FACSIMILE: (415) 981-4840 April 7, 2005 BY EDGAR, FACSIMILE AND OVERNIGHT DELIVERY Mr. Andrew Schoeffler Division of Corporation Finance, Mail Stop 4-4 Securities and Exchange Commission 450 Fifth Street. N.W. Washington, D.C. 20549 Facsimile: 202-942-9531 Re: ATEL Capital Equipment Fund XI, LLC Registration Statement on Form S-1 SEC File No. 333-120276 Dear Mr. Schoeffler: Concurrently with this letter we have filed by EDGAR requests to accelerate the effectiveness of the above-referenced registration statement to April 11, 2005 or as soon thereafter as may be practicable. Please contact me with any questions or comments you may have concerning this filing. Very truly yours, Paul J. Derenthal cc: Mr. Dean L. Cash Ms. Merriah Harkins