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CORRESP
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CNL Strategic Capital,
LLC

450 South Orange Avenue

Orlando, Florida 32801

    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

    October 29, 2024

Re: Request
                                            for Acceleration of Effectiveness

                                            CNL Strategic Capital, LLC

  Registration Statement on Form S-1

  (File No. 333-277103)

Dear Mr. Stickel
and Ms. Block:

In
accordance with Rule 461 of the General Rules and Regulations under the Securities Act of 1933, as amended (the “Securities Act”),
CNL Strategic Capital, LLC (the “Company”) hereby requests that the effectiveness for the above-captioned Registration Statement
on Form S-1 (as amended through the date hereof) filed under the Securities Act be accelerated to 11:00 a.m., New York City time, on
November 1, 2024, or as soon thereafter as practicable. The Company also requests the Commission to specifically confirm such effective
date and time to the Company in writing.

If
you have any questions regarding the foregoing, please contact Jason D. Myers of Clifford Chance US LLP, counsel to the Company, at (212)
878-8324.

    Very truly yours,

    CNL STRATEGIC CAPITAL, LLC

    By:
    /s/ Chirag J. Bhavsar

    Name: Chirag J. Bhavsar
Title: Chief
    Executive Officer