SecProbe.io

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      November 26, 2004

Mail Stop 0510

via U.S. Mail and facsimile

Dean L. Cash
Chief Executive Officer
ATEL Capital Equipment Fund X, LLC
600 California Street, 6th Floor
San Francisco, CA 94108

      Re: 	ATEL Capital Equipment Fund X, LLC
      	Post-Effective Amendment No. 4 to Form S-1 filed October
27, 2004
		File No. 333-100452

Dear Mr. Cash:

      We have reviewed your filing and have the following
comments.
Where indicated, we think you should revise your document in
response
to these comments.  If you disagree, we will consider your
explanation as to why our comment is inapplicable or a revision is
unnecessary.  Please be as detailed as necessary in your
explanation.
In some of our comments, we may ask you to provide us with
supplemental information so we may better understand your
disclosure.
After reviewing this information, we may or may not raise
additional
comments.

      Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.

General

1. Please update the financial statements based on interim data
through September 30, 2004 in accordance with Rule 3-12 of
Regulation
S-X.

Supplement Dated 8/31/2004, Financial Statements

2. We note that on page F-14 of the supplement dated August 31,
2004,
you refer to three major customers, to each of whom sales
accounted
for more than 10% of your revenue in 2003.  Please revise your
disclosure to identify these customers by name and relationship,
if
any, to you and your affiliates in accordance with Item
101(c)(1)(vii) of Regulation S-K.

      As appropriate, please amend your registration statement in
response to these comments.  You may wish to provide us with
marked
copies of the amendment to expedite our review.  Please furnish a
cover letter with your amendment that keys your responses to our
comments and provides any requested supplemental information.
Detailed cover letters greatly facilitate our review.  Please
understand that we may have additional comments after reviewing
your
amendment and responses to our comments.

      We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings reviewed by the staff to
be
certain that they have provided all information investors require
for
an informed decision.  Since the company and its management are in
possession of all facts relating to a company`s disclosure, they
are
responsible for the accuracy and adequacy of the disclosures they
have made.

	Notwithstanding our comments, in the event the company
requests
acceleration of the effective date of the pending registration
statement, it should furnish a letter, at the time of such
request,
acknowledging that:

?	should the Commission or the staff, acting pursuant to
delegated
authority, declare the filing effective, it does not foreclose the
Commission from taking any action with respect to the filing;

?	the action of the Commission or the staff, acting pursuant to
delegated authority, in declaring the filing effective, does not
relieve the company from its full responsibility for the adequacy
and
accuracy of the disclosure in the filing; and

?	the company may not assert this action as a defense in any
proceeding initiated by the Commission or any person under the
federal securities laws of the United States.

	In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in connection with our review of
your
filing or in response to our comments on your filing.

      We will consider a written request for acceleration of the
effective date of the registration statement as a confirmation of
the
fact that those requesting acceleration are aware of their
respective
responsibilities under the Securities Act of 1933 and the
Securities
Exchange Act of 1934 as they relate to the proposed public
offering
of the securities specified in the above registration statement.
We
will act on the request and, pursuant to delegated authority,
grant
acceleration of the effective date.

      We direct your attention to Rules 460 and 461 regarding
requesting acceleration of a registration statement.  Please allow
adequate time after the filing of any amendment for further review
before submitting a request for acceleration.  Please provide this
request at least two business days in advance of the requested
effective date.

      You may contact Jeanne Baker at (202) 942-1835 if you have
questions regarding comments on the financial statements and
related
matters.  Please contact Matt Franker at (202) 824-5495, Mark Webb
at
(202) 942-1874, or me at (202) 942-1950 with any other questions.

      			Sincerely,

      			Pamela Ann Long
      					Assistant Director

cc:	Paul J. Derenthal, Esq. (via facsimile 415/981-4840)
      Derenthal & Dannhauser, LLP
	One Post Street, Suite 575
	San Francisco, CA 94104
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Dean L. Cash
ATEL Capital Equipment Fund X, LLC
November 26, 2004
Page 1

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-0404

         DIVISION OF
CORPORATION FINANCE

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