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SEC Company Response from ATEL Capital Equipment Fund XI, LLC (CIK 0001297667) — Mar 25, 2005

ATEL Capital Equipment Fund XI, LLC (CIK 0001297667)
Date: March 25, 2005 · CIK: 0001297667 · Accession: 0001011723-05-000037

AI Filing Summary & Sentiment

File numbers found in text: 333-120276

Referenced dates: March 8, 2005

Date
March 25, 2005
Author
Paul J. Derenthal
Form
CORRESP
Company
ATEL Capital Equipment Fund XI, LLC (CIK 0001297667)

Letter

March 25, 2005 BY OVERNIGHT DELIVERY AND EDGAR 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:

We are responding to comments on supplemental sales materials set forth in Ms. Long's letter dated March 8, 2005. The numbered responses below correspond to the numbered comments in the letter.

4. Enclosed are complete copies of the proposed supplemental sales materials, as revised through the date of this letter.

5. We have attempted to integrate the cover page risk factors throughout the text of the materials. In the case of the PowerPoint presentation, we have included required "talking points" to be used with the slides in order to address some of the qualifications of potential benefits noted in the slides.

6. See the revised prospecting letters.

Please contact us with any further comments you may have in this regard or to notify us that you have cleared all outstanding comments.

Very truly yours,
Paul J. Derenthal

Show Raw Text
<DOCUMENT>
<TYPE>CORRESP
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>

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

                                 March 25, 2005

BY OVERNIGHT DELIVERY AND EDGAR

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:

         We are responding to comments on supplemental sales materials set forth
in Ms. Long's letter dated March 8, 2005. The numbered responses below
correspond to the numbered comments in the letter.

         4. Enclosed are complete copies of the proposed supplemental sales
materials, as revised through the date of this letter.

         5. We have attempted to integrate the cover page risk factors
throughout the text of the materials. In the case of the PowerPoint
presentation, we have included required "talking points" to be used with the
slides in order to address some of the qualifications of potential benefits
noted in the slides.

         6. See the revised prospecting letters.

         Please contact us with any further comments you may have in this regard
or to notify us that you have cleared all outstanding comments.

                                        Very truly yours,

                                        Paul J. Derenthal

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

</TEXT>
</DOCUMENT>