[graphic omitted]
ATEL
Financial Services, LLC
August 17, 2009
BY EDGAR AND OVERNIGHT DELIVERY
Mr. Rufus Decker
Accounting Branch Chief
Division of Corporation Finance, Mail Stop 4631
Securities and Exchange Commission
450 Fifth Street. N.W.
Washington, D.C. 20549-4631
Re: ATEL Capital Equipment Fund XI, LLC (the "Company")
Form 10-K for the fiscal year ended December 31, 2008
Form 10-Q for the period ended March 31, 2009
SEC File No. 0-51858
Dear Mr. Decker:
This letter is in response to your letter dated August 7, 2009,
addressed to me as Chief Financial Officer of the above-referenced Company,
regarding the referenced reports.
The Company's supplemental response to the comment in your letter is
set forth below.
FORM 10-K FOR THE FISCAL YEAR ENDED DECEMBER 31, 2008
Exhibit 31
1. Attached supplementally is the Company's Form 10-K/A filed concurrently
with this letter to include the required certifications, complete with
the previously omitted phrases.
Please contact the undersigned with any further comments or questions
concerning the Company's reports.
Very truly yours,
ATEL Capital Equipment Fund XI, LLC
By: ATEL Financial Services, LLC, its Manager
/s/ Paritosh K. Choksi
-----------------------------
By: Paritosh K. Choksi, Executive Vice President
600 California Street, 6th Floor, San Francisco, CA 84108 Main 415.989.8800
Facsimile 415.989.3796 www.atel.com
Mr. Rufus Decker
August 17, 2009
Page 2
cc: Ms. Nudrat Salik
Staff Accountant
Division of Corporation Finance, Mail Stop 4631
Securities and Exchange Commission
Paul J. Derenthal, Esq.
Mr. Samuel Schussler
Mr. Tullus Miller