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CORRESP
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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

 May 19, 2025

 David Manion, CPA, CAIA

 Karen Rossotto, Senior Counsel

 Securities and Exchange Commission

 Division of Investment Management

 100 F Street NE

 Washington, DC 20549

 Re: Destiny Tech100 Inc.

 Pre-Effective
Amendment No. 2 to Registration Statement on Form N-2

 File Nos. 811-23802; 333-278734

 Dear Mr. Manion and Ms. Rossotto:

 On behalf of
Destiny Tech100 Inc. (the "Company"), set forth below are the Company's responses to the accounting and legal comments
provided orally by the staff of the Division of Investment Management (the "Staff") of the Securities and Exchange Commission
(the "SEC") on December 17, 2024, regarding Pre-Effective Amendment No. 2 to the Company's registration statement on
Form N-2 (the "Registration Statement"), including the preliminary prospectus contained therein (the "Prospectus"),
which was filed on EDGAR on November 19, 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.

 Attached herein is a copy of the Pre-Effective
Amendment No. 3 to the Company's registration statement on Form N-2 (the "Amended Registration Statement"), including
the Prospectus contained therein, which was filed on EDGAR on May 19, 2025.

 ACCOUNTING COMMENTS

 General

 1. We refer to your response to Comment No. 1 from our prior comment letter. While
we agree that the investments in special purpose vehicles ("SPVs") should not be consolidated in the Company's financial
statements, your analysis should be revised as follows:

 a. The reference to 946-10-55-5
should be revised as that section refers to operating companies; and

 b. Where you state that you
"measure investments" at fair value, please revise to indicate whether this refers to the fair value of the SPV or the fair
value of the underlying securities.

 Response: The Company acknowledges the
Staff's concurrence that the investments held by the Company through SPVs should not be consolidated in the Company's financial
statements. In order to address the Staff's comments, the analysis previously provided to the Staff has been revised as set forth
below:

 The Company has concluded that it is not appropriate
to consolidate any of the special purpose vehicles ("SPVs") through which it has invested and believes that its presentation
of such investments in the schedule of investments on an unconsolidated basis is consistent with GAAP and is the most meaningful presentation
of such investments for readers of the Company's financial statements.

 1

 David Manion, CPA, CAIA
 Karen Rossotto, Senior Counsel
 May 19, 2025
 Page 2

 Evaluating Whether SPVs are a Variable Interest
Entity ("VIE") that Require Consolidation

 The Company has reviewed its investments held
in Special Purpose Vehicles ("SPVs") in order to determine whether they should be consolidated. In evaluating, the Company
first considered IM Guidance Update No. 2014-11 issued by the SEC, which contains the views of the Chief Accountant of the SEC's
Division of Investment Management as to when it is appropriate for an investment company in a fund of funds or master-feeder structure
to consolidate another investment company. The IM Guidance Update No. 2014-11 states, "In the circumstances of a fund of funds,
generally, the staff has taken the position that the financial presentation that is most meaningful also is unconsolidated." The
staff has taken a similar position for feeder funds, as outlined in IM Guidance No. 2014-11. Accordingly, the IM Guidance Update No. 2014-11
supports that an unconsolidated presentation for the SPVs would be the most meaningful presentation to the users of the Company's
financial statements.

 Moreover, the Company considered the guidance
set forth under ASC 810, Consolidation , ("ASC 810"), under the presumption that the consolidation scope exception
under ASC 810-10-15-12(d) is not met and that the SPVs qualify as variable interest entities ("VIEs") in scope under ASC 810,
in order to evaluate whether it has a controlling financial interest in any of the SPVs by applying the variable interest model under
ASC 810.

 In accordance with ASC 810-10-25-38, an entity
is deemed to be the primary beneficiary of a VIE if it has both of the following characteristics: (a) the power to direct the activities
of a VIE that most significantly impact the VIE's economic performance, and (b) the obligation to absorb the majority of losses
of the VIE or the right to receive the majority of benefits from the VIE.

 The Company concluded that it was not the primary
beneficiary of any of the SPVs due to the following key factors:

 · The sole purpose of the SPVs is to pool investor
capital to invest in securities of a single pre-determined private company and to engage in any and all activities necessary, incidental,
proper, advisable or convenient to the foregoing. The activities and decisions that most significantly impact economic performance of
the SPVs are conducted by the Manager of each SPV. The Manager of each SPV is responsible for the management and day-to-day administration
and operations of the SPV. Additionally, the Manager of each SPV has the power and authority to exclusively manage, control and direct
the SPV and all of its business, affairs, activities and operations. The Company has no role in the formation or operation of the SPV,
has no power with respect to the appointment of the Manager and cannot unilaterally replace the Manager.

 · The Company was not involved in the design of
any of the SPVs.

 · The Company does not have investment discretion
or voting rights with respect to any of the SPVs.

 Therefore, under the presumption that the Company
was subject to ASC 810 and applied the VIE model, the above factors support that the Company would not be considered the primary beneficiary
for each SPV and therefore would not be required to consolidate any of the SPVs.

 2. We refer to your response to Comment No. 1 from our prior comment letter. We disagree with your analysis
related to the presentation of the investments in SPVs in the schedule of investments. We believe it is materially misleading to list
the underlying issuer in the schedule of investments rather than the SPV through which the Company invests. Please restate prior financial
statements accordingly and amend prior N-PORT filings that include the underlying issuer as the entity in which the Company invested.

 David Manion, CPA, CAIA
 Karen Rossotto, Senior Counsel
 May 19, 2025
 Page 3

 Response: The Company acknowledges the
Staff's comment and has revised in the annual report to shareholders included in its Form N-CSR for the year ended December 31,
2024 filed on March 25, 2025, its presentation of the investments it holds through SPVs to list each individual SPV in the schedule of
investments along with a parenthetical that shows the private company to which the Company gains exposure as a result of the investment
in the SPV.

 In addition, after the filing of the amended Registration Statement, the
Company will file an amended N-CSR for the year ended December 31, 2023 and an amended N-CSRS for the period ended June 30, 2024 that
include restated financial statements that revise the presentation of the investments held through SPVs in the schedule of investments
to that included in the Form N-CSR for the year ended December 31, 2024. As will be noted in the amended N-CSR and N-CSRS, the Company
evaluated whether any changes to the fair values of the SPVs were warranted and determined that the fair values were appropriately recorded,
so no changes to the fair values of such investments were recorded. The Company will make amended Form N-PORT filings as requested.

 3. We refer to your response to Comment No. 3 from our prior comment letter. We do not agree that the
investment in OpenAI was held at December 31, 2023. Please amend the Form N-PORT accordingly.

 Response: The Company acknowledges the
Staff's comment and will amend the Form N-PORT accordingly.

 LEGAL COMMENTS

 4. Please review and revise your disclosure in the Prospectus to accurately indicate ownership of companies
owned through SPVs.

 Response: The Company has revised the portfolio
company table beginning on page 18 of the Prospectus included in the Amended Registration Statement that accompanies this letter so that
the presentation conforms to the schedule of investments included in the Company's financial statements included in its Form N-CSR
for the year ended December 31, 2024.

 5. We refer to your response to Comment No. 10 from our prior comment letter. In correspondence, please
tell us how many primary rounds the Company has invested in to date. In addition, please conform disclosure on your website to the disclosure
included in the Prospectus in response to prior comments.

 Response: The Company advises the Staff that as of December 31, 2024, seven of
the Company's investments in private issuers or 13.4% of such investments, were acquired through primary purchases as opposed to secondary
purchases.

 6. We refer to the Prospectus cover page where you indicate that, as of the date hereof, no investments
were made in "Private Funds." In light of the fact that SPVs generally rely on Section 3(c)(1) of 3(c)(7) of the Investment
Company Act of 1940 in order to not register as investment companies, please consider whether this disclosure is accurate.

 Response: The Company has revised its disclosure
to clarify that the reference to "Private Funds" refers to investments made in private equity funds, venture funds and hedge
funds. Specifically, the Company has added the following language to the cover page of the Prospectus included in the Amended Registration
Statement: "SPVs that we invest in are generally exempt from registration pursuant to Section 3(c)(1) or Section 3(c)(7) of the
1940 Act."

 7. We refer to page 7 of the Prospectus where you state that "Investments in SPVs are common in
the venture capital industry and are an efficient way to pool capital with other investors in order to invest in a single issuer."
Please revise to make clear that in these situations, your investment is in the SPV and not directly in the underlying issuer.

 Response: The Company has revised its disclosure
accordingly.

 8. Please update your disclosure in the Prospectus to reflect September 30, 2024 rather than June 30,
2024.

 David Manion, CPA, CAIA
 Karen Rossotto, Senior Counsel
 May 19, 2025
 Page 4

 Response: The Company has updated its disclosure
in the Amended Registration Statement that accompanies this letter so that it refers to December 31, 2024.

 9. We refer to the last bullet point on page 15 of the Prospectus under the heading, "Risks Associated
with Investments in Private Funds." Please disclose, if accurate, that the value of the SPV may be different than the value of the
underlying securities and that the Company has no ownership rights with respect to the underlying securities.

 Response: The Company has included disclosure
in the Prospectus included in the Amended Registration Statement that accompanies this letter as requested.

 10. We refer to footnote 1 to the portfolio company table that refers to the "Fund." Please
clarify whether this should refer instead to the "Company."

 Response: The Company has revised in the
Prospectus included in the Amended Registration Statement that accompanies this letter its disclosure to change the reference from "Fund"
to "Company."

 11. We refer to Comment No. 14 from our prior comment letter. Please confirm that you will disclose the
Company's net asset value as of the date of each offering made from the shelf registration statement and not merely rely on the
net asset value as of the most recent quarter end.

 Response: The Company confirms that it
will calculate its net asset value with sufficient frequency in order to ensure that sales of its common stock are made consistent with
the provisions found in Section 23(b) of the Investment Company Act of 1940, as amended. Specifically, the Company is aware that relying
solely on the prior quarter end net asset value will not be sufficient for purposes of complying with Section 23(b).

 *	 * *

 If you have
any questions or additional comments concerning the foregoing, please contact me at (202) 383-0262.

 Sincerely,

 /s/ Owen J. Pinkerton

 Owen J. Pinkerton

 cc:

 Steven B. Boehm, Esq., Eversheds Sutherland (US)
 LLP
 Sohail Prasad, Destiny Tech100 Inc.