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    Eversheds Sutherland (US) LLP

    700 Sixth Street, NW, Suite 700

    Washington, DC 20001-3980

    D: +1 202.383.0262

    F: +1 202.637.3593

    owenpinkerton@eversheds-sutherland.us

June 24, 2024

Karen Rossotto, Senior Counsel

Securities and Exchange Commission

Division of Investment Management

100 F Street NE

Washington, DC 20549

 Re: Destiny Tech100 Inc.

Registration Statement
on Form N-2

File Nos. 811-23802; 333-278734

Dear Ms. Rossotto:

On behalf of Destiny
Tech100 Inc. (the “Company”), set forth below are the Company’s responses to the comments provided by the staff of the
Division of Investment Management (the “Staff”) of the Securities and Exchange Commission (the “SEC”) on May 21,
2024, regarding the Company’s registration statement on Form N-2 (the “Registration Statement”), which was filed on
April 16, 2024. The Staff’s comments are set forth below and are followed by the Company’s responses. Capitalized terms used
but not defined herein have the meanings ascribed to such terms in the Registration Statement.

LEGAL COMMENTS

General

 1. In a Bloomberg TV interview last month you noted the Company was created to provide investors “as
close to beta exposure to the private markets as possible”. However, disclosures on your website generally state your intention:

…to invest in a portfolio of
100 of the top venture-backed private technology companies, providing…investors access to these private market leaders …
companies must have been vetted by top U.S. institutional investors and meet key health metrics

… [and] generally have reached
a level of maturity and stability expected of a late- stage venture backed company [emphasis added].

Existing prospectus disclosure similarly
suggests an intention to actively select companies that meet narrower selection criteria. Please reconcile the apparent inconsistency
and revise investor facing communications as necessary.

Response: The Company confirms that its investment
strategy is to invest in a portfolio of the top venture-backed private technology companies that meet criteria set forth in the Company’s
filings with the SEC. While Mr. Prasad’s statement differs from the language found in the Company’s public filings, the Company
does not believe it is material or misleading. Due to the large number of technology companies that qualify as so-called “unicorn”
private companies, providing investor access to a portfolio that seeks to invest in up to 100 of such private technology companies can
be viewed as exposure to the private markets in general. The Company does not use the phrase “as close to beta exposure to the private
markets as possible” in any of its marketing materials, nor does it include such statement on its website. Since the Company does
not believe that the interview with Mr. Prasad was material or misleading, and since the Company is not conducting an offering of its
securities, the Company does not believe that any statements or filings are necessary to address the inconsistency.

      1

    Karen Rossotto, Senior Counsel

    June 24, 2024

    Page 2

 2. Disclosure on the website indicates that for many pre-IPO stage companies, “there may be the
potential to yield a 10-50% return.” Please provide us the basis for this statement and otherwise explain why such statement is
appropriate and not misleading.

Response: The referenced language specifically
states that for “many” pre-IPO companies “there may be the potential” for such a return, which is clearly not
a guarantee of any specific return nor does it suggest that “all” pre-IPO companies will achieve such gains. The context where
the referenced language appears within the website is distinguishing between “large cap” companies (valued at $10B+) and “medium
cap” companies (valued at $750M-10B). The statement is based on the venture lifecycle where companies that are at the medium cap
stage “may have the potential” for such growth. While the Company does not believe such statement is misleading to investors,
it has removed such statement from its website.

Cover

 3. As the securities being registered will be offered “on a delayed or continuous basis”,
please check the second box on the Cover indicating registration in reliance on Rule 415 under the Securities Act. If this box is not
checked, please explain to us why not. In addition, please include the Undertakings required by Item 34.3 of Form N-2. In connection with
the Plan of Distribution-related Undertaking, please tell us whether you anticipate offering, selling, or otherwise promoting the sale
of securities of the Company generally other than through registered broker-dealers or persons employed by the Company. If so, please
tell us your intentions and the types of disclosures that will be provided to investors in connection with such activity.

Response: The Amendment has been revised to
check the box on the facing page indicating that shares may be offered on a delayed or continuous basis. The Amendment has also been revised
to include the Undertakings set forth in Item 34.3 of Form N-2. The Company has no current intention to offer shares from the shelf registration
statement except through registered broker-dealers or individuals employed by the Company or an affiliate.

 4. In the third paragraph on page i, the disclosure indicates the Company may sell common stock at a price
below NAV “in connection with a rights offering to our existing stockholders.” Does the Company anticipate such an offering?
Please confirm to us.

Response: The Company has no current plans
to conduct a rights offering of its shares. However, since the shelf registration statement has a three-year term, the Company would like
the flexibility to consider such an offering under appropriate market conditions. The Company believes it is customary to allow for a
rights offering off a shelf registration statement.

 5. On page i, in the first line of the fourth paragraph, the disclosure states “Our common stock
may be offered…through agents designated from time to time by us, or to or through underwriters or dealers.” Please explain
to us who these “agents” are, what they do and how they are compensated. Please also explain to us the distinction between
the agents and underwriters/dealers referenced in the disclosure. In addition, please let us know if the agents and/or underwriters have
or will be provided information, access, scripts, or marketing materials by the Company and whether and to what extent the Company or
the Adviser monitors their activities.

    Karen Rossotto, Senior Counsel

    June 24, 2024

    Page 3

Response: The Company advises the Staff that
the referenced language is standard language included in shelf registration statements and is designed to provide the Company with flexibility
to access the capital markets on a timely basis if attractive opportunities are available. The Company believes that the term “agent”
could refer to different entities, such as a placement agent or a sales agent, which would be a registered broker-dealer. A placement
agent would differ from an underwriter in that it would not engage in a firm commitment underwritten offering of securities, but instead
would seek to raise capital through a best efforts offering of securities, including through an “at-the-market offering” (see
the response to comment 8(a) below). In addition, securities could be issued through a subscription agent in a registered rights offering.
As noted on page i of the Prospectus, “Each prospectus supplement relating to an offering will identify any agents or underwriters
involved in the sale of our securities, and will disclose any applicable purchase price, fee, discount or commissions arrangement between
us and our agents or underwriters or among our underwriters or the basis upon which such amount may be calculated. See “Plan of
Distribution.” We may not sell our common stock through agents, underwriters or dealers without delivery of this prospectus and
a prospectus supplement describing the method and terms of the offering of our common stock.” No such arrangements are in place
or being negotiated. As the issuer of securities, the Company would of course be responsible for monitoring the activities of an agent
or underwriter selling or facilitating the sale of its shares. However, as no arrangements are currently in place, the Company is unable
to disclose the nature and extent of such monitoring activities.

 6. On page i, in the fifth (bolded) paragraph, the disclosure provides the Company’s last reported
share price as of April 12, 2024. Please update this paragraph, and disclosure in general throughout the prospectus, to reflect events
that have occurred since the registration statement was filed.

Response: The Amendment has included updated
disclosure with respect to its share price and to reflect any material events since the initial filing of the Registration Statement.

 7. On page ii, please disclose within the bolded bullets, that, in addition to the Company’s shares
having traded at a premium to net asset value, the Company’s shares have also exhibited high price volatility.

Response: The Company has revised its disclosure
on the cover page, as requested.

About the Prospectus (page 4)

 8. The disclosure in the third sentence of this paragraph states

We may sell our common stock through
underwriters or dealers, “at-the-market” to or through a market maker, into an existing trading market or otherwise directly
to one or more purchasers or through agents or through a combination of methods of sale.

Regarding this disclosure, please address
the following comments:

 a. Please explain to us what “at-the-market” means and how this price is determined.

Response: The Company advises the Staff that
an “at-the-market” offering (“ATM”) is a follow-on registered offering of shares on a continuous basis through
a registered broker-dealer engaged by the issuer. The shares sold in an ATM offering are sold pursuant to an equity distribution agreement
(or sales agreement) whereby the broker-dealer(s) sell shares into the market in exchange for a commission paid by the issuer or an affiliate.
The terms of any such sales, including the price (or range of prices) at which shares may be sold, will be dictated by a placement notice
that the issuer provides to the broker-dealer in advance of any sales made pursuant to the ATM. To the extent the Company engages in an
ATM offering, it will only issue placement notices requiring that shares be sold at a price, net of commissions, that is not below the
current net asset value of the Company. ATM offerings are a very common method of raising incremental capital over time.

    Karen Rossotto, Senior Counsel

    June 24, 2024

    Page 4

 b. Please explain to us what the phrase “an existing trading market” refers to (i.e., what
trading market (or markets) does the Company anticipate trading in?)

Response: The Company advises the Staff that
“existing trading market” only refers to the NYSE; however, if the Company’s shares are sold through a different securities
exchange, such market would be included as well. Since the shelf registration statement is valid for three years, the Company believes
it is appropriate and not confusing to investors to retain the disclosure as is.

 c. Please explain to us what “directly to one or more purchasers” means. In doing so, please
explain how these sales are made and who these purchasers are.

Response: The Company advises the Staff that
the shelf registration statement would allow the Company to directly sell shares to one or more purchasers with or without the use of
a registered broker-dealer. Such sales would be described more fully in a prospectus supplement. Purchasers could be institutions or individuals
that are interested in purchasing a large block of shares, which would either be impossible or disruptive to the trading market if done
through normal buy orders.

Prospectus Summary

Investment Strategy (page 6)

 9. The disclosure in the penultimate sentence of the second paragraph states “We will limit our investments in…Private
Funds to no more than 15% of our net assets.” Please confirm that when determining the Company’s exposure to Private Funds
with respect to this limitation, the Company will look through to any Private Fund investments held in any SPVs the Company is invested
in. In addition, as many of the Company’s investments are in SPVs that invest substantially all of their assets in securities, please
tell us what exemptions from the Investment Company Act such SPVs rely on and whether you consider them Private Funds for purposes of
the 15% limitation.

Response: The Company confirms that, to the
extent any SPV in which it invests holds shares of a Private Fund, the Company will include such investment in the 15% limitation included
in the Prospectus. The Company notes, however, that it has no intention of investing in an SPV that holds shares of a Private Fund. The
Company believes that the SPVs it invests in generally rely on the exclusions found in Section 3(c)(1) or 3(c)(7) under the 1940 Act,
and the Company does not include them in the definition of “Private Funds” in the Prospectus. The Company is aware of the
Staff’s position promulgated through comment letters limiting investments by registered funds in private equity funds and hedge
funds to 15% of the issuer’s net assets, or in some cases, total assets.

 10. In the third paragraph, the disclosure references “forward contracts for future delivery of stock.”
Please explain here what these transactions are and what they involve.

Response: The Company has revised its disclosure
under “Investment Strategy” to provide an overview of forward contracts for future delivery of stock.

Investment Types (page 7)

    Karen Rossotto, Senior Counsel

    June 24, 2024

    Page 5

 11. To assist investors in understanding your portfolio, strategy, and risks, please disclose the approximate
percentage of the portfolio purchased (1) directly from a portfolio company (2) indirectly through an employee or former employee and
(3) indirectly through an institutional investor. Depending on your response, please consider the need for improved risk disclosure regarding
your access to portfolio company information and/or risks related to transfer restrictions on employee and investor shares.

Response: The Company has included additional
disclosure under the heading “Summary—Current Portfolio” to provide details regarding the portion of the portfolio acquired
through an SPV managed by a third party and the portion of the portfolio invested in SPVs that own forward contracts. In addition, the
Company has included additional disclosure under “Summary—Investment Types” regarding risks associated with the investments
in SPVs. The Company has included disclosure regarding the portion of its portfolio comprised of investments in SPVs managed by third
parties, but does not believe that separately disclosing the portion of its portfolio comprised of securities of an employee or former
employee of a portfolio company or the portion purchased indirectly through an institutional investor is meaningful to investors in the
Company.

 12. In the penultimate line of the second paragraph, the disclosure indicates that the Company will seek
approval for direct purchases from stockholders of shares that may have limitations and restrictions that you describe in the paragraph.
Please explain to us if the Company will always seek approval when purchasing shares in this way, or will the Company purchase shares
without approval, including through forward agreements?

Response: The Company has revised its disclosure
to make clear that the Company will seek approval from an underlying portfolio company if such approval is required by the agreement the
Company has with the shareholder of such portfolio company. In addition, the Company has provided ad