SecProbe.io

CORRESP
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    1900 K Street, NW

                           Washington, DC 20006-1110

+1 202 261 3300 Main

+1 202 261 3333 Fax

www.dechert.com

William J. Bielefeld

william.bielefeld@dechert.com

+1 202 261 3386 Direct

+1 202 261 3333 Fax

March 29, 2024

VIA EDGAR

Ms. Megan Miller

U.S. Securities and Exchange Commission

Division of Investment Management

100 F Street, NE

Washington, D.C. 20549

Re: Pomona Investment Fund (the “Fund”)

(File Nos. 333-271207;
811-22990)

Dear Ms. Miller:

This letter responds to the comments of the staff
(the “Staff”) of the Securities and Exchange Commission (the “Commission”) provided telephonically
on February 29, 2024, relating to the Fund’s Annual Reports for the fiscal years ended March 31, 2022 and March 31, 2023, as filed
with the Commission on Form N-CSR on June 9, 2022 (Accession No. 0001398344-22-011828) and on June 8, 2023 (Accession No. 0001398344-23-011783),
respectively.

1. Comment: The Staff noted that
                                the net expense ratio for certain of the Fund’s share classes appears to be greater than the gross
                                expenses in the fee table. When funds pay back any previously-waived expenses, the Staff believes that
                                the recaptured fees should be presented on a standalone line item as an expense of the Fund (or in a
                                separate line item within “Other Expenses”) and reflected in the Fund’s gross expense
                                ratio, as the recoupment of previously-waived fees is an expense of the Fund. Please explain how the
                                fee table was prepared and update accordingly.

Response:
The Fund confirms that, in future filings, it will reflect the recoupment of expenses as a separate
line item in the fee and expense table and include such expenses in the Fund’s gross expense ratio.

    Ms. Megan Miller

    March 29, 2024

    Page 2

2. Comment: Please consider listing
                                each unfunded commitment separately by portfolio company.

Response:
The Fund will add a footnote to the Schedule of Investments in future filings identifying each investment
that has an unfunded commitment.

3. Comment: Please use updated
                                Form N-CSR going forward. Specifically, Item 4(i) and 4(j) were missing. Even if the information requested
                                by these items is not applicable, the items should be shown.

Response:
The Fund will use the updated Form N-CSR for future shareholder reports.

4. Comment: Item 11(b) incorrectly
                                references “second fiscal quarter”. Please revise the disclosure to cover the entire period
                                covered by the report.

Response:
The Fund will reflect this change to Item 11(b) in an amended N-CSR filing.

5. Comment: Please include all
                                required disclosure relating to investments in restricted securities. Specifically, in the footnotes
                                to the Consolidated Schedule of Investments, in addition to presenting the aggregate fair value of all
                                restricted securities, please also disclose percentage which the aggregate fair value bears to net assets.

Response:
The Fund respectfully notes that it currently discloses the percentage which the aggregate fair value
bears to net assets following the heading “Private Equity Investments” in the Consolidated Schedule of Investments. Nevertheless,
the Fund will also disclose the percentage which the aggregate fair value bears to net assets in the relevant footnote in future filings.

6. Comment: Please include one
                                or more tables, charts or graphs depicting the portfolio holdings by reasonable identifiable categories
                                per Item 24 of Form N-2.

Response:
The Fund will include one or more tables, charts or graphs depicting the portfolio holdings by reasonably
identifiable categories in future filings.

    Ms. Megan Miller

    March 29, 2024

    Page 3

7. Comment: The Staff noted that
                                the Fund has a loan payable as of period end. Regulation S-X Item 4-08(b) states that assets mortgaged,
                                pledged, or otherwise subject to lien, and the approximate amounts thereof, shall be designated and the
                                obligations collateralized briefly identified. Please explain where that disclosure is in the financial
                                statements.

Response:
The Fund will add a footnote to the Schedule of Investments in future filings identifying each investment
that is held by Pomona Investment Fund, LLC, a wholly-owned subsidiary of the Fund, and, accordingly, is indirectly pledged as collateral
in connection with the Fund’s revolving credit agreement.

*                                *                                *

We believe that the foregoing has been responsive
to the Staff’s comments. Please call the undersigned at (202) 261-3386 if you wish to discuss this correspondence further.

Sincerely,

/s/ William J. Bielefeld

William J. Bielefeld

cc:           Frances
Janis, Pomona Investment Fund