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May 17, 2024
George Schrade
Principal Financial Officer
Graham Alternative Investment Fund II LLC
c/o Graham Capital Management, L.P.
40 Highland Avenue
Rowayton, CT 06853
Re:Graham Alternative Investment Fund II LLC
Form 10-K for the Fiscal Year Ended December 31, 2023
File No. 000-53967
Dear George Schrade:
            We have limited our review of your filing to the financial statements and related
disclosures and have the following comments.
            Please respond to this letter within ten business days by providing the requested
information or advise us as soon as possible when you will respond. If you do not believe a
comment applies to your facts and circumstances, please tell us why in your response.
            After reviewing your response to this letter, we may have additional comments.
Form 10-K for the Fiscal Year Ended December 31, 2023
Graham Alternative Investment Fund II LLC
Core Macro Portfolio
Financial Statements, page 40
1.You only provided financial statements for Core Macro Portfolio, one of the series of
Graham Alternative Investment Fund II LLC (the registrant). Please revise future filings
to also include financial statements for the registrant, Graham Alternative Investment
Fund II LLC. Refer to Question 104.01 of the Compliance and Disclosure Interpretations
for Securities Act Section.
Item 9A. Controls and Procedures, page 103
2.Please revise the disclosure in future filings regarding your evaluation of the effectiveness
of disclosure controls and procedures and internal control over financial reporting to
present your conclusions for both the series and the registrant. In addition, you should
include in this section a statement whether the principal executive officer and principal

 FirstName LastNameGeorge Schrade
 Comapany NameGraham Alternative Investment Fund II LLC
 May 17, 2024 Page 2
 FirstName LastName
George Schrade
Graham Alternative Investment Fund II LLC
May 17, 2024
Page 2
financial officer certifications are applicable to the series as well as to the registrant. Refer
to Question 104.01 of the Compliance and Disclosure Interpretations for Securities Act
Section.
Exhibits
3.Refer to Exhibits 31.1 and 31.2. Please revise future filings to include the introductory
language in paragraph 4, referring to internal control over financial reporting.
            In closing, we remind you that the company and its management are responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or
absence of action by the staff.
            Please contact Kate Tillan at 202-551-3604 or David Irving at 202-551-3321 with any
questions.
Sincerely,
Division of Corporation Finance
Office of Crypto Assets