SecProbe.io

CORRESP
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Brian T. London

Of Counsel

+1.215.963.5886

brian.london@morganlewis.com

December 27, 2024

FILED AS EDGAR CORRESPONDENCE

Alison T. White, Esq.

U.S. Securities and
Exchange Commission

100 F Street, NE

Washington, D.C. 20549

Re: The Advisors’ Inner Circle Fund III 485(a) Filing (File
Nos. 033-192858 and 811-22920)

Dear Ms. White:

On behalf of our client, The Advisors’ Inner
Circle Fund III (the “Trust”), this letter responds to the comments you provided on behalf of the staff (the “Staff”)
of the Securities and Exchange Commission (the “SEC”) via telephone, regarding the Trust’s post-effective amendment
no. 365, under the Securities Act of 1933, as amended (the “1933 Act”), and amendment no. 369, under the Investment Company
Act of 1940, as amended (the “1940 Act”), to its registration statement filed with the SEC pursuant to Rule 485(a) under the
1933 Act (the “Amendment”) with respect to the Knights of Columbus U.S. All Cap Index Fund (the “Fund”), a series
of the Trust. Below, we have briefly summarized your comments and questions, followed by our responses. Where indicated, certain of the
responses are based on information provided by Knights of Columbus Asset Advisors LLC (the “Adviser”) and L2 Asset Management,
LLC (the “Sub-Adviser”) for the specific purpose of responding to the Staff’s comments. Capitalized terms not defined
herein should be given the meaning provided in the Amendment.

 1. Comment.	 Please advise whether the Fund will be changing its name to reflect the change
in the underlying index from the Knights of Columbus U.S. All Cap Index (the “Prior Index”) to the Bloomberg U.S. 3000 Catholic
Values Index (the “New Index”). If so, please revise the disclosure as appropriate.

Response.	 The Fund does
not currently intend to change its name to reflect the New Index.

 2. Comment.	 Please bold the second sentence of the preamble in the “Fund Fees and
Expenses” section of the Prospectus per Item 3 of Form N-1A.

Response.	The
Fund has made the requested revision.

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Alison T. White, Esq.

December 27, 2024

Page 2

 3. Comment.	 In the “Principal Investment Strategies” section, please disclose
(i) the approximate number of constituents in the New Index; (ii) the weighting methodology of the Bloomberg U.S. 3000 Index, the Index’s
parent index (the “Parent Index”); and (iii) the average weighted market capitalization and range of market capitalizations
of the Parent Index.

Response.	The “Principal
Investment Strategies” section has been updated to disclose that (i) as of November 30, 2024, the New Index consisted of approximately
2,666 constituents; (ii) the Parent Index is a free-float market-capitalization-weighted index; and (iii) as of November 30, 2024, the
market capitalizations of the Parent Index ranged from approximately $18 million to $3.6 trillion, and its average weighted market capitalization
was approximately $900.5 billion.

 4. Comment.	 Please supplementally provide the Staff with the New Index methodology.

Response.	The Trust has
supplementally provided the Staff with the New Index methodology.

 5. Comment.	 With reference to the United States Conference of Catholic Bishops’ Socially
Responsible Investing Guidelines (the “USCCB guidelines”):

(i).	Please supplementally provide a
description of the USCCB guidelines, including the role they play in the construction of the New Index. For instance, how specific are
the guidelines, and are all of the guidelines followed? Also, what do the guidelines say about contraception? Do the guidelines identify
specific products, companies or categories for exclusion, or is that determination made by the New Index?

Response.	The USCCB guidelines
outline principles to be followed when evaluating whether potential investments follow Catholic social teaching. Broadly, the guidelines
provide direction in key areas: Protecting Human Life, Promoting Human Dignity, Acting Justly, Enhancing the Common Good and Caring for
the Environment. The guidelines also provide direction on actions to be taken by investors: Do No Harm, which requires avoidance
of investment or divestment, Actively Work for Change, which allows investment but recommends engagement with company management
to influence corporate culture and shape policies and decisions, and Promote the Common Good, which recommends supporting policies
that match Catholic moral teaching and/or making community development investments that do the same.

With respect to the role the USCCB guidelines
play in the construction of the New Index, the New Index excludes companies that violate the criteria outlined in the USCCB guidelines.
The USCCB guidelines identify specific activities that should be avoided for investment. Bloomberg Index Services Limited (“Bloomberg”
or “BISL”), the index provider, contracts with Morningstar Sustainalytics to apply the USCCB guidelines and determine which
companies meet the exclusions criteria. The construction methodology of the New Index fully implements the USCCB guidelines and provides
BISL with sole discretion to determine which securities are eligible for exclusion.

Alison T. White, Esq.

December 27, 2024

Page 3

With reference to contraception, the
USCCB guidelines restrict investment in companies that have any kind of involvement in the production of contraceptives or derive
more than 10% of revenue from the sale of contraceptives.

	(ii).	Please
supplementally explain if there are any USCCB guidelines that are not being implemented fully.

	Response.	The
Adviser confirms that the construction methodology of the New Index fully implements the USCCB guidelines.

(iii).	Please consider revising the disclosure
to address any sector tilts in favor of, or against, a sector that arise from excluding issuers based on the USCCB guidelines.

Response.	The Fund has
revised the “Principal Investment Strategies” disclosure in the Prospectus to clarify that the application of the USCCB guidelines
may, from time to time, result in the Index being underweight certain sectors (such as the health care sector) or overweight certain sectors
(such as the information technology sector) relative to the Parent Index.

 6. Comment.	 Given that the Parent Index includes the 3,000 U.S. companies with the largest
free-float market capitalizations, please confirm that “All Cap” is still appropriate in the Fund’s name.

Response.	The Adviser
confirms that the phrase “All Cap” remains appropriate for inclusion in the Fund’s name. The Adviser notes that
both the Prior Index and the New Index include small-cap, mid-cap, and large cap companies. Specifically, as of November 30, 2024,
the market capitalization range of the Prior Index was approximately $33 million to $3.6 trillion, and the market capitalization
range of the New Index was approximately $18 million to $3.6 trillion. Accordingly, the Adviser believes that the phrase “All
Cap” appropriately represents the Fund’s investment universe under both the Prior Index and New Index.

Alison T. White, Esq.

December 27, 2024

Page 4

 7. Comment.	 With reference to the first sentence of the second paragraph in the “Principal
Investment Strategies” section, please disclose the other “enterprises” that conflict with the USCCB Guidelines. Please
also summarize the USCCB guidelines in the Prospectus.

	Response.	The
first sentence of the second paragraph in the “Principal Investment Strategies” section has been replaced with the following
sentence:

The Index consists of all
common stocks and real estate investment trusts (“REITs”) in the Bloomberg U.S. 3000 Index (the “Parent Index”),
excluding companies that are determined by Bloomberg Index Services Limited (“Bloomberg” or “BISL”) and Morningstar
Sustainalytics (“Sustainalytics”) to be involved with activities that conflict with the USCCB Guidelines, including gambling,
abortion, contraception, pornography and other forms of adult entertainment, stem cell and fetal tissue research/human cloning, tobacco,
cannabis, weapons of mass destruction and other forms of controversial weapons, manufacturing and selling of weapons to civilians (the
“Restricted Securities List”), or other activities that may be added to the Restricted Securities List from time to time.

In addition, a summary of the USCCB guidelines
has been added to the “More Information about the Fund’s Investment Objectives and Strategies” section of the Prospectus.

Alison T. White, Esq.

December 27, 2024

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 8. Comment.	 The “Principal Investment Strategies” section states that the Fund
will concentrate its investments (i.e., hold 25% or more of its total assets) in a particular industry or group of industries to approximately
the same extent that the New Index is so concentrated. If the New Index is currently concentrated, please add appropriate principal investment
strategy and risk disclosure.

Response.	The Adviser confirms
that as of November 30, 2024, the New Index is not concentrated in a particular industry or group of industries. Therefore, the Fund has
not made disclosure changes in this regard.

 9. Comment.	Please confirm if the “Small- and Mid- Capitalization Company Risk”
disclosure remains applicable given that the Parent Index includes the 3,000 U.S. companies with the largest free-float market caps.

Response.	The Adviser confirms
that the “Small- and Mid- Capitalization Company Risk” disclosure remains applicable to the Fund given the constituents of
the New Index.

 10. Comment.	 With reference to the “Equity Risk” disclosure in the “More
Information about Risk” section:

(i). The first sentence states: “Equity
securities include public and privately issued equity securities, common and preferred stocks, warrants, rights to subscribe to common
stock, convertible securities, depositary receipts and shares of real estate investment trusts ("REITs").” If the
Fund may principally invest in any of these securities, please add corresponding disclosure to the Principal Investment Strategies and
Principal Risks sections.

Response.	The Fund
has removed privately-issued securities, preferred stocks, convertible securities, depositary receipts, and warrants and rights
from the above-referenced sentence because they are not principal investments of the Fund.

(ii). The last sentence states: “Depositary
receipts and REITs are discussed elsewhere in this section,” although this does not appear to be the case. Please delete this
sentence or include the referenced disclosure if appropriate.

Response.	The Fund separately
discusses risks relating to REITs in this same section under “Real Estate Investment Trusts Risk.” However, the Fund has
deleted the reference to depositary receipts from the above-referenced sentence.

 11. Comment. 	With reference to the “Indexing Strategy/Index Tracking Risk” in
the “More Information about Risk” section, the second sentence refers to the Prior Index. Please revise the disclosure accordingly.

	Response.	The
Fund has revised the disclosure to refer to the New Index.

Alison T. White, Esq.

December 27, 2024

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 12. Comment. 	The disclosure under “Information about Portfolio Holdings” states
that “The Adviser may exclude any portion of the Fund’s portfolio holdings from such publication when deemed in the best
interest of the Fund.” Please provide the legal basis for doing so.

	Response.	The
referenced disclosure relates to the list of the Fund’s ten largest portfolio holdings that is voluntarily posted on its website,
rather than the quarterly portfolio holdings disclosure that is required by applicable law. To make that more clear, the Trust has revised
the second sentence of the referenced section to clarify that website publication of the Fund’s portfolio holdings is "in addition
to disclosure required by applicable law as discussed in the SAI." In addition, the Trust has added the following sentence to the
end of the referenced section: "Nevertheless, as described in the SAI, the Fund will disclose its complete portfolio holdings quarterly,
within 60 days of the end of each fiscal quarter." In light of the foregoing, the Trust believes that the section includes appropriate
disclosure with respect to this matter.

 13. Comment. 	Please consider removing the “Dormant Multi-Manager Arrangement”
disclosure.

	Response.	The
Trust respectfully declines to remove the disclosure because the standard shareholder approval condition of the multi-manager exemptive
orders requires that a fund’s public shareholders purchase shares on the basis of a prospectus containing the disclosure where,
as here, the multi-manager arrangement is approved by the initial shareholder of the fund before the fund’s shares are offered to
the public.

 14. Comment. 	In the “Taxes” section of the Prospectus, the Staff notes that
there are references to the Knights of Columbus Real Estate Fund. Please advise or revise the disclosure accordingly.

Response.	The Fund has
deleted all references to the Knights of Columbus Real Estate Fund from the Prospectus.

 15. Comment. 	Please file any index license agreements as an exhibit.

Response.	The Registrant
does not believe the index license agreement is required to be filed because the Registrant and the Fund are not parties to the license
agreement and, therefore, has not filed the license agreement as an exhibit to the registration statement.

* * * * * * * * * * * *

If you have any questions, need any additional information
or would like any clarification, please contact me at (215) 963-5886.

Very truly yours,

    /s/ Brian T. London

    Brian T. London