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CLIFFORD
CHANCE US LLP

March
29, 2024

VIA
EDGAR

Mr.
John Stickel, Esq.

Ms.
Susan Block, Esq.

United
States Securities and Exchange Commission

Division
of Corporation Finance

100
F Street, N.E.

Washington,
D.C. 20549-0404

 Re: CNL
                                            Strategic Capital, LLC

                                            Registration Statement on Form S-1

                                            Filed February 15, 2024

    File No. 333-277103

    Responses to Staff comments made by letter dated March 13, 2024

Dear
Mr. Stickel and Ms. Block:

On
behalf of our client, CNL Strategic Capital, LLC (the “Company”), set forth below are the responses of the Company
to comments made by the staff (the “Staff”) of the Securities and Exchange Commission (the “SEC”)
by letter dated March 13, 2024 (the “Comment Letter”) in connection with the Company’s Registration Statement
on Form S-1 (File No. 333-277103) (the “Registration Statement”), which was filed on February 15, 2024. Defined terms
used herein but not otherwise defined have the meanings ascribed to them in the prospectus.

The
Company’s responses to the Staff’s comments contained in the Comment Letter are set out in the order in which the comments
were set out in the Comment Letter and are numbered accordingly. The Company will amend the Registration Statement at a later date to
reflect the proposed changes noted herein.

Prospectus
Summary

Will
there be a liquidity event for shareholders, page 13

 1. We
                                            note your disclosure that the board of directors intends to contemplate a liquidity event
                                            for your shareholders on or before November 1, 2027. Please clarify if it is anticipated
                                            that it can occur at any time before November 1, 2027, including shortly after the offering.

In
response to the Staff’s comment, the Company supplementally advises the Staff that the current disclosure provides that the board
of directors intends to contemplate a liquidity event on or before November 1, 2027, which covers any time before such date. In the prospectus
relating to the Company’s initial public offering, the Company disclosed that the board of directors intends to contemplate a liquidity
event for its shareholders “within six years from the date [the Company] terminate[s] this offering.” The Company’s
initial public offering was terminated on November 1, 2021 and six years thereafter is November 1, 2027.

CLIFFORD
CHANCE US LLP

Mr.
John Stickel, Esq.

Ms.
Susan Block, Esq.

United
States Securities and Exchange Commission

March
29, 2024

Page
2

The
decision to consider a liquidity event is subject to the discretion of the board of directors. As such, the Company advises the Staff
that it does not have any additional information to provide at this time regarding the expected timing of any such decision, and therefore
the Company believes that the current disclosure is accurate and complete.

Are
there any Investment Company Act of 1940 considerations, page 15

 2. Please
                                            note that we have referred your filing to the Division of Investment Management and may have
                                            further comments.

The
Company acknowledges the Staff’s comment.

Prior
Performance of the Manager, the Sub-Manager and Their Respective Affiliates, page 56

 3. We
                                            note that you have presented in this section the historical experience of certain programs
                                            sponsored or managed in the last ten years by CNL affiliates and LLCP and its affiliates.
                                            We also note from your disclosure that you indicate the purpose of this prior performance
                                            information is to enable investors to evaluate accurately the experience of CNL affiliates
                                            and LLCP and its affiliates in sponsoring programs. Please revise the disclosure regarding
                                            prior performance so that it reflects the performance of CNL Strategic Capital, LLC, rather
                                            than predecessor affiliated programs. Given the time that has elapsed since your initial
                                            public offering, it appears that investors should have sufficient information to make an
                                            informed investment decision based upon your performance rather than being directed towards
                                            the prior performance or experience of CNL, LLCP or any affiliates. In this regard, we also
                                            note the disclosure that many of the discussed affiliate programs do not share comparable
                                            business strategies or business objectives with you. As such, please remove disclosure related
                                            to prior performance that is not directly yours, and rather focus your disclosure on the
                                            performance of CNL Strategic Capital, LLC. Alternatively, provide support as to why you believe
                                            such disclosure remains materially relevant to investors.

In response to the Staff's comment, the Company supplementally advises the Staff that it agrees with the Staff that disclosure of the
Company’s performance to investors is important information that investors can take into account when deciding whether they should
purchase common shares of the Company in the offering. The Company advises the Staff that the Company already includes performance information
of the Company under the section captioned “Management’s Discussion and Analysis of Financial Condition and Results of Operations—Results
of Operations—Total Returns” on page 87 of the prospectus. Additionally, the Company has supplemented and will continue to
supplement such performance information of the Company on a monthly basis in a current report on Form 8-K, which information is incorporated
by reference in the prospectus.

CLIFFORD
CHANCE US LLP

Mr.
John Stickel, Esq.

Ms.
Susan Block, Esq.

United
States Securities and Exchange Commission

March
29, 2024

Page
3

However,
the Company also believes that the historical experience of programs sponsored or managed by Levine Leichtman Capital Partners, LLC (“LLCP”)
that have similar business objectives to the Company provides investors meaningful information to help them make an informed investment
decision.

The
Company is externally managed by CNL Strategic Capital Management, LLC and sub-managed by Levine Leichtman Strategic Capital, LLC, an
affiliate of LLCP. The Company’s business strategy is to primarily acquire controlling equity interests in middle-market businesses
located in the United States. It is important to note that the Company’s business strategy is the same strategy that has been used
by LLCP in relation to the Private Acquisition Funds, which are described under the section captioned “Prior Performance of the
Manager, the Sub-Manager and Their Respective Affiliates—Prior Programs Sponsored by LLCP and its Affiliates—Private Acquisition
Funds” beginning on page 59 of the prospectus. LLCP has executed on this business strategy over many different business cycles.

Additionally,
the Company continuously offers its common shares through the retail distribution channel in order to raise capital to grow its business.
The Company’s Managing Dealer for the offering engages broker-dealers and registered investment advisers to sell common shares
in the offering. Participating broker-dealers and registered investment advisers have requested information about LLCP (including the
historical experience of programs sponsored by it) and have indicated that this information is relevant and material for purposes of
conducting due diligence to determine whether to participate in the Company’s offering and offer this investment to their respective
clients. In particular, the Company uses the historical experience of programs sponsored or managed by LLCP that have similar business
objectives to the Company (as disclosed in the prospectus) to educate broker-dealers, registered investment advisers and other distribution
participants about LLCP’s track record, and they rely on this information when assessing the suitability of an investment in the
Company. The Company also understands that investors rely on this information to learn about LLCP , which helps them better understand
the Company’s business objective and strategy when deciding whether they should purchase common shares of the Company in the offering.
Additionally, because the Company has not yet sold any asset acquired during its operating history, participating broker dealers and
registered investment advisers have regularly requested information on sales of investments by programs sponsored or managed by LLCP
that have similar business objectives to the Company in order to assess LLCP’s prior experience with exiting investments. However,
none of this information is publicly available. Accordingly, the Company believes that the historical experience of programs sponsored
or managed by LLCP that have similar business objectives to the Company supplements in a meaningful way, rather than distracts from,
the performance information of the Company already included in the prospectus.

CLIFFORD
CHANCE US LLP

Mr.
John Stickel, Esq.

Ms.
Susan Block, Esq.

United
States Securities and Exchange Commission

March
29, 2024

Page
4

The
Company acknowledges the Staff’s view that prior performance information should be limited to information that is most likely to
be material to investors (CF Disclosure Guidance: Topic No. 6). Therefore, in response to the Staff’s comment and based on the
discussion above, the Company proposes to revise the disclosure to remove the sections captioned “Prior Performance of the Manager,
the Sub-Manager and Their Respective Affiliates” and “Appendix A: Prior Performance Tables” and include disclosure
relating only to the Private Acquisition Funds that is currently in the prospectus in a new sub-section captioned “Management—Historical
Experience of LLCP and its Affiliates” beginning on page 118 of the prospectus, substantially as set forth on Annex A hereto
(which will be updated as of 12/31/2023).

Share
Repurchase Program, page 80

 4. We
                                            note your disclosure that the Share Repurchase Program includes certain restrictions on the
                                            timing, amount and terms of your repurchases intended to ensure your ability to qualify as
                                            a partnership for U.S. federal income tax purposes. Please disclose any such restriction
                                            that are not already otherwise discussed in this section. Consistent with your disclosure
                                            on page 179, please also disclose here that you cannot terminate the share repurchase program
                                            absent a liquidity event or where otherwise required by law, but that the board of directors
                                            has the right to amend or suspend the share repurchase program to the extent it determines
                                            that it is in our best interest to do so upon 30 days’ prior notice to your shareholders.
                                            Further, clarify whether any shareholder requests for repurchase have not been honored since
                                            inception.

In
response to the Staff’s comment, the Company supplementally advises the Staff that there are no other restrictions not already
discussed in the prospectus regarding the Share Repurchase Program as they relate to ensuring the Company’s ability to qualify
as a partnership for U.S. federal income tax purposes.

Additionally,
the Company proposes to add disclosure in a new paragraph two under the section captioned “Management’s Discussion and Analysis
of Financial Condition and Results of Operations—Share Repurchase Program” beginning on page 80 of the prospectus, substantially
as set forth on Annex B hereto. The Company also proposes to add disclosure at the end of existing paragraph three under the section
captioned “Management’s Discussion and Analysis of Financial Condition and Results of Operations—Share Repurchase Program”
as set forth below:

“We
have had no unfulfilled share repurchase requests under the Share Repurchase Program since inception.”

CLIFFORD
CHANCE US LLP

Mr.
John Stickel, Esq.

Ms.
Susan Block, Esq.

United
States Securities and Exchange Commission

March
29, 2024

Page
5

General

 5. We
                                            note that throughout your filing you discuss various types of fees related to both the shares
                                            themselves, as well as in the form of the management fees. In an effort to provide greater
                                            clarity, please provide disclosure that groups together all of the various types of fees
                                            in one place so that potential investor can better understand your overall fee structure.
                                            Also provide illustrative examples of how your overall fee structure relates to potential
                                            investors of each of the respective classes of shares in the summary section or advise.

In
response to the Staff’s comment, the Company proposes to revise the disclosure under the section captioned “Prospectus Summary—What
is the difference between the Class A, Class T, Class D, Class I, Class FA and Class S shares?” beginning on page 11 of the
prospectus to include a table that provides an illustrative example of how the Company’s fee structure relates to potential investors
of each of the respective classes of shares, substantially as set forth on Annex C hereto. The Company also proposes to revise
the disclosure under the section captioned “Prospectus Summary—What are the fees that we pay to the Manager, the Sub-Manager,
their respective affiliates and the Managing Dealer in connection with this offering?” beginning on page 11 of the prospectus to
include the same table that is currently in the prospectus on page 138 under the section captioned “Compensation of the Manager,
the Sub-Manager and the Managing Dealer” that summarizes the compensation, reimbursements and distributions the Company pays to
the Manager, the Sub-Manager, the Managing Dealer and affiliates, substantially as set forth on Annex D hereto.

Should
the Staff have any additional questions or comments regarding any of the foregoing, please do not hesitate to contact the undersigned
at (212) 878-8324.

 Sincerely,

 /s/
Jason D. Myers

 Jason
D. Myers

 cc: CNL
Strategic Capital, LLC

Chirag
J. Bhavsar

Tracey
Bracco

Bradley
Yochum

Clifford
Chance US LLP

Jay
L. Bernstein

Tae
Ho Cho

CLIFFORD
CHANCE US LLP

Mr.
John Stickel, Esq.

Ms.
Susan Block, Esq.

United
States Securities and Exchange Commission

March
29, 2024

Page
6

ANNEX
A

Historical
Experience of LLCP and its Affiliates

The
information presented herein represents the historical experience of programs sponsored or managed in the last ten years by LLCP and
its affiliates, through December 31, 2022, except as otherwise indicated, that have similar business objectives to us (the "Private
Acquisition Funds"). The purpose of this prior performance information is to enable investors to evaluate accurately the experience
of LLCP and its affiliat