SecProbe.io

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                         SIDLEY AUSTIN BROWN & WOOD LLP

  BEIJING                        BANK ONE PLAZA                      LOS ANGELES
                            10 S. DEARBORN STREET
  BRUSSELS                  CHICAGO, ILLINOIS 60603                     NEW YORK
                            TELEPHONE 312 853 7000
  CHICAGO                    FACSIMILE 312 853 7036                SAN FRANCISCO
                                www.sidley.com
   DALLAS                                                               SHANGHAI
                                 FOUNDED 1866
   GENEVA                                                              SINGAPORE

 HONG KONG                                                                 TOKYO

   LONDON                                                       WASHINGTON, D.C.

WRITER'S DIRECT NUMBER                                   WRITER'S E-MAIL ADDRESS

                                October 11, 2005

Mr. Owen Pinkerton
 Senior Counsel
Ms. Amanda McManus
 Attorney-Advisor
United States Securities and
 Exchange Commission
100 "F" Street, N.W.
Washington, D.C.  20549

           Re:      Man-AHL 130, LLC (the "Pool")
                    Registration Statement on Form S-1
                    Filed June 28, 2005
                    File No. 333-126172

Dear Mr. Pinkerton:

         We thank the Staff for its July 28, 2005 comment letter on the
above-referenced filing. The following are the Staff's comments -- repeated
verbatim for your convenience of reference -- followed by our responses. In many
cases, of course, the responses refer to a corresponding change in Amendment No.
1 to the Registration Statement filed hereto.

         "General

         1.       It is not clear why you refer to Man-AHL as the "Fund" since
                  you assert in your disclosure on page ii that the pool is not
                  a mutual fund registered under the Investment Company Act of
                  1940, and given that the term "Fund" is not part of the pool's
                  name. Please revise to refer to the pool by its name or a
                  variation of its name."

         Public commodity pools have commonly -- in fact, almost uniformly --
referred to themselves as "funds" in their prospectuses. We do not feel that
"fund" in any respect necessarily connotes "mutual fund." There are, for
example, numerous real estate funds, private equity funds, insurance funds, etc.
On the other hand, the term "pool" is used very infrequently

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SIDLEY AUSTIN BROWN & WOOD LLP                                           CHICAGO

Mr. Owen Pinkerton
Ms. Amanda McManus
United States Securities and
 Exchange Commission
October 11, 2005
Page 2

-- indeed, hardly at all outside of the regulations of the Commodity Futures
Trading Commission ("CFTC"). Experience strongly argues that no investor will be
misled by the Prospectus referring to the Pool as the "Fund," while the use of
the term "Pool" would be unusual.

         The reason that the term, "fund," is omitted from the name of the Pool
is that Man Group plc ("Man") -- which has approximately $43 billion under
management -- has traditionally identified its investment funds without
including the term "fund" in the title of these collective investment vehicles.
A number of U.S. commodity pools have done so as well, and we would much prefer
to continue this approach as Man, through its U.S. subsidiary Man Investments
(USA) Corp. (the "Managing Member"), inaugurates its public U.S. marketing with
the Pool. The fact that the term "fund" does not appear in the title of the Pool
does not indicate that the use of this term in the body of the Prospectus would
be inappropriate. On the contrary, of the three likely possibilities "Company,"
"Fund" or "Pool," "Fund" seems the most appropriate.

         2.       In light of your intention to invest 30 percent of the
                  proceeds of this offering in Man-Glenwood Lexington, a
                  closed-end mutual fund registered under the Investment Company
                  Act of 1940, please provide us with a detailed legal analysis
                  of why you do not believe you should register as an investment
                  company under the Investment Company Act of 1940. In
                  connection with this, please provide us with additional
                  details of the types of investments made by Man-Glenwood
                  Lexington and whether these investments include securities as
                  defined by the '33 Act.

         We have responded under separate cover, by letter of August 9, 2005
(the "Section 3(b)(1) Letter"), regarding the status of the Pool under Section
3(b)(1) of the Investment Company Act of 1940, as well as had several
discussions with the Staff on this point. We are, of course, available at your
convenience for such follow-up as the Staff may deem appropriate. Ms. Susan
Olson is the Staff Member from Investment Management with whom we have been
dealing.

         3.       In light of the fact that up to 30 percent of your investments
                  will be in Man-Glenwood Lexington, it is not clear why you
                  have not provided disclosure in Part One of the disclosure
                  document regarding the investment objectives and performance
                  history of Man-Glenwood Lexington and Man-Glenwood Lexington
                  TEI. Please revise to include

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SIDLEY AUSTIN BROWN & WOOD LLP                                           CHICAGO

Mr. Owen Pinkerton
Ms. Amanda McManus
United States Securities and
 Exchange Commission
October 11, 2005
Page 3

                  substantially greater disclosure regarding the types of
                  investments made by these entities in all relevant portions of
                  the prospectus, including the summary, as well as capsule
                  performance disclosure. We note your limited disclosure on
                  page 13 but do not believe that this provides sufficient
                  information to investors regarding the nature of
                  Man-Glenwood's investment strategy.

         As will be clear from the Section 3(b)(1) Letter, although the Pool has
allocated 30% of its capital to Man-Glenwood Lexington, LLC ("MGL"), MGL
represents only approximately between 4% and 11% of the Pool's market exposure.
Accordingly, we believe that detailed descriptions of MGL in the Prospectus
would overstate the importance of MGL to an investor in the Pool. We are also
concerned that including different disclosures concerning MGL in the Pool's
Prospectus from that set forth in MGL's own Prospectus (MGL is publicly offered
pursuant to an effective registration order under the Securities Act of 1933
(the "1933 Act")) could raise significant disclosure/liability concerns for Man.

         We propose to address the Staff's concerns regarding the MGL
disclosures in the Prospectus by including relevant portions of the current
Prospectus of MGL as an Appendix to the Prospectus.

         The Staff should be aware that the National Futures Association (the
"NFA") in its review of the Prospectus (which is subject to NFA review under
Part 4 of the CFTC regulations ("Part 4")) raised analogous issues regarding the
MGL disclosure. The NFA has agreed that we may use excerpts from the Prospectus
in order to satisfy the CFTC disclosure requirements. We are, of course, glad to
include as much disclosure concerning MGL as the Staff feels is appropriate, but
are concerned that prospective investors might, as a result of more extensive
disclosure, exaggerate the importance of MGL in the Pool's portfolio. In
particular, we feel that it is important that the prospective investors clearly
understand that the capital allocation to MGL overstates its importance in the
Pool's portfolio given the leverage of the Pool's managed futures component --
in which the Pool acquires market exposure of approximately 300%-800% of its
total equity, as opposed to the approximately 36% market exposure acquired
through its investment in MGL.

         As the MGL Prospectus is sufficient disclosure for persons investing
solely in MGL, we assume that relevant portions of the MGL Prospectus will, a
fortiori, be considered adequate from the SEC's perspective for investors in the
Pool. As you will see, by "relevant" we mean disclosures which relate to MGL
itself, as opposed to general matters such as tax and which are independently
covered in the Prospectus. It would be hard to justify providing inconsistent
disclosures to these two groups of investors.

<PAGE>
SIDLEY AUSTIN BROWN & WOOD LLP                                           CHICAGO

Mr. Owen Pinkerton
Ms. Amanda McManus
United States Securities and
 Exchange Commission
October 11, 2005
Page 4

         4.       Please revise throughout the prospectus to provide disclosure
                  substantially similar to the disclosures that would be
                  required by Industry Guide 5 if real estate limited
                  partnership units were being registered. For example, your
                  revisions should include a narrative discussion under an
                  appropriate major heading of the managing member and its
                  affiliates' experience over the past ten years similar to that
                  required by Item 8.A of Guide 5, which includes a description
                  of any major adverse business developments and conditions that
                  were experienced.

         We are aware from numerous other public commodity pool filings of the
Staff's position that the disclosures regarding these commodity pools should be
comparable to those which would be made under Guide 5 in the case of
registration statements relating to real estate limited partnerships. We attach
as an Appendix to this letter a cross-reference sheet indicating where in the
Prospectus the Guide 5 disclosures (as and to the extent applicable) are
included.

         As the Pool is also subject to Part 4, we have attempted to conform the
Prospectus disclosure to both Part 4 and Guide 5 (Part 4, for example, requiring
certain disclosures to be made in the "forepart" of the Prospectus).

         Regarding the Staff's specific reference to Section 8 of Guide 5, Part
4 includes specific requirements regarding the past performance of a commodity
pool's advisor and sponsor, and we have complied with Part 4 in this filing. As
the CFTC rules are specific on the question of the disclosure of past
performance, the Staff has in prior commodity pool filings found CFTC-required
disclosures to be acceptable.

         Insofar as "major adverse business developments" are concerned, there
have been none -- either in respect of Man (which is newly-formed) or any of its
affiliates (which have been in continuous operation since the late 1700s).
Consequently, we have not made any disclosures responsive to Section 8(A)(2) of
Guide 5. We have never read Guide 5 to require affirmative statements that there
is nothing to disclose -- e.g., "There have been no major adverse business
developments with regard to Man or its affiliates within the last 10 years."
Part 4 used to require such statements, but was amended to eliminate them, as it
was understandably confusing to a prospective investor to be told affirmatively
that there is nothing to disclose. We would request that the Staff permit us to
follow this approach -- i.e., if there is no Guide 5 disclosure to be made,
nothing needs to be included in the Prospectus. Certainly this has been found to
be acceptable practice in past filings.

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SIDLEY AUSTIN BROWN & WOOD LLP                                           CHICAGO

Mr. Owen Pinkerton
Ms. Amanda McManus
United States Securities and
 Exchange Commission
October 11, 2005
Page 5

         5.       Please provide us with a complete copy of any sales material
                  which includes all illustrations and other inserts in the form
                  you expect to distribute to investors in accordance with
                  Release No. 33-6900 and by analogy to Item 19D of Guide 5. We
                  may have further comment after we receive your materials.

         We are providing the Staff under separate cover with the currently
proposed sales material for the Pool. This material will also be filed with the
NASD. As in the past, we have ensured that all disclosures in the sales material
are directly derivable from information in the Prospectus. We have also ensured
that the disclosures in the sales material are consistent with the NASD's
statements in the Altegris and Citigroup enforcement actions (which have
effectively prohibited the use of certain previously commonly-used disclosures
such as "targeted returns," and required "bullet point" risk factors).

         6.       Please supplementally confirm to us, if true, that all units
                  redeemed or otherwise re-acquired by the trust will not be
                  re-issued to other investors. If you do intend to re-issue
                  redeemed or re-acquired units, please tell us supplementally
                  how you intend to register those re-issuances under the
                  Securities Act.

         We confirm that units once redeemed are not reissued. There is no
equivalent of "Treasury Shares" in the case of partnership interests -- either
an interest exists and is outstanding or it does not. All units are issued only
once, and the number of units which may be issued is limited by the amounts
which are registered for public offering under the 1933 Act.

         7.       Please confirm to us that, following effectiveness of the
                  registration statement and the breaking of escrow, you will
                  file a prospectus supplement each month reflecting the net
                  asset value at which you sell your units.

         There have been numerous continuously offered public commodity pools --
indeed, in our experience, the substantial majority of pools, other than
"principal protected" pools which often have a single "principal protection
date" and, accordingly, a single issuance date for the units, are continuously
offered. Part 4 requires that the Prospectus be accompanied -- once a pool has
begun operating -- by CFTC monthly reports required to be delivered to existing
investors and current within 60 days. These monthly reports contain summary
performance information for the pool in question. We have in the past routinely
filed these

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SIDLEY AUSTIN BROWN & WOOD LLP                                           CHICAGO

Mr. Owen Pinkerton
Ms. Amanda McManus
United States Securities and
 Exchange Commission
October 11, 2005
Page 6

monthly reports under Rule 424(c) as a supplement to the Prospectus, and would
propose to do so in the case of the Pool as well.

         Please let us know if we have misunderstood the Staff's comment, and
the Staff is requesting a filing procedure with respect to the Part 4 monthly
reports different from that which the industry has been permitted to use in the
past.

         8.       Please advise us supplementally whether the managing member or
                  its affiliates can purchase units in the offering so as to
                  reach the minimum subscription. If so, please also disclose
                  this fact in all relevant sections of the prospectus,
                  including the cover page and the summary.

         Man and its affiliates do not intend to invest in the Pool (other than
as discussed below in response to Staff Comment 12), and were they to do so the
units purchased by them would not be counted towards the "escrow break." In
previous filings in which we have permitted units acquired by the sponsor of a
pool or related party to be counted in determini