SecProbe.io

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                                 LAW OFFICES OF
                           DERENTHAL & DANNHAUSER LLP
                           ONE POST STREET, SUITE 575
                         SAN FRANCISCO, CALIFORNIA 94104
                                 (415) 981-4844
                            FACSIMILE: (415) 981-4840

                                  March 7, 2005

BY EDGAR AND OVERNIGHT DELIVERY

Ms. Pamela A. Long
Assistant Director
Division of Corporation Finance, Mail Stop 4-4
Securities and Exchange Commission
450 Fifth Street. N.W.
Washington, D.C. 20549

                  Re:      ATEL Capital Equipment Fund XI, LLC
                           Pre-Effective Amendment No. 2 to
                           Registration Statement on Form S-1
                           SEC File No. 333-120276

Dear Ms. Long:

         Enclosed with the hard copy of this letter are changed pages to the
following supplemental sales materials previously filed for your review:

         -        Sales Brochure
         -        Prospecting Letter no. 1
         -        Tri-fold Brochure
         -        PowerPoint presentation

         This letter will supplement our responses to your comment letter dated
February 22, 2005, by addressing comments 10 through 20 relating to the
supplemental sales materials received by you January 27, 2005.

         10. We have attempted to incorporate all comments on the registration
statement into the revised materials, including updating the risk factor
disclosure.

         11. We have reviewed all of the materials to present a balanced
discussion, appropriate to the context, in all the materials. See for example
the revision to Prospecting Letter #1.

         12. See our responses to this comment in our letter dated March 2,
2005, accompanying our filing of pre-effective amendment no. 3 to the
registration statement. We have made the necessary revisions to the prospectus
and/or the sales materials.

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Ms. Pamela A. Long
March 7, 2005
Page 2

         13. See the revision to the tri-fold brochure.

         14. See the revision to the tri-fold brochure.

         15. See the revised materials. The intention is to state that equipment
leasing investments are almost exclusively the province of institutional
investors. Only a small fraction of such investments are made through investment
pools available to individuals. We would note that under Investment Objectives
and Policies - Leasing Industry and Competition" in the prospectus, after
describing the institutional sources of lease financing, the registrant states
that "public programs like the Fund represent only a relatively small portion of
the lease financing industry."

         16. This slide has been deleted.

         17. The partial list of lessees and examples of prior program
investments were selected to illustrate the types of lessees and typical
transactions by prior programs with the same investment objectives. The first
slide includes a cross reference to Table V in Exhibit A to the prospectus.
Table V reflects that these lessees and transactions are in fact typical of the
ATEL programs' business and investments.

         18. The list of risk factors has been so revised.

         19. See the response to comment 17. Again, these transactions are
typical transactions that will illustrate and assist in an understanding of the
registrant's investment objectives and policies.

         20. See the revised page.

                  Please contact me with any further questions or comments you
may have concerning this filing.

                                        Very truly yours,

                                        Paul J. Derenthal

cc:      Mr. Paritosh Choksi
         Mr. Andrew Schoeffler
         Ms. Merriah Harkins
         Mr. Daniel Courtney

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