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    WTI FUND X, INC.

    104 LA MESA DR., SUITE 102

    PORTOLA VALLEY, CA  94028

    November 13, 2024

    VIA EDGAR

    Mr. John Kernan

    Staff Accountant

    Disclosure Review Office

    Division of Investment Management

    U.S. Securities and Exchange Commission

    3 World Financial Center

    New York, New York 10281

          Re:

            WTI Fund X, Inc.

    Dear Mr. Kernan:

    Set forth below are our responses to the comments (restated in italics below) that you imparted during a telephone conversation with us on October 1, 2024, relating to the Annual Report on Form 10-K
      (“Form 10-K”) of WTI Fund X, Inc. (“Fund”) for the year ended December 31, 2023.  Thank you for providing us with your comments and for giving us the opportunity to respond to them in this letter (“Response Letter”).

          1.

            Comment.     Please explain why the practice of promptly distributing in-kind warrants granted and/or equities
                received is in the best interests of beneficial shareholders (as compared to continuing to manage these investments in the Fund). In your response, please describe any material differences in the terms of incentive or performance fees paid
                by shareholders of WTI Fund X, LLC as compared to fees charged by the Fund.

    Response.

    The practice of promptly distributing in-kind warrants granted and/or equities received is in the best interests of beneficial shareholders (as compared to continuing to manage these investments in
      the Fund) for several reasons.  As described in the Form 10-K, the Fund is a wholly-owned subsidiary of WTI Fund X, LLC, a Delaware limited liability company (the “Company”).  Accordingly, all gains and losses created at either the Fund level or the
      Company level are fully consolidated at the Company level for purposes of calculating returns to shareholders. Further, for purposes of this response, we note that neither the Fund nor the Company charge performance or incentive fees to
      shareholders.  The Management Fees charged to both the Fund and the Company are calculated as a percentage of committed capital, and thus are not impacted by where the warrants and equity investments are held.

          Mr. John Kernan

          November 13, 2024

          Page 2

    As further described in the Form 10-K, the Fund primarily provides debt financing to venture-backed companies (“Portfolio Companies”), generally in the form of secured loans.  In most cases, the Fund
      will receive warrants for equity securities of the Portfolio Company in connection with the loan.

    The warrants create an opportunity for beneficial shareholders of the Company to earn returns from the appreciation of the Portfolio Companies.  It has been the experience of the Fund’s investment
      adviser, Westech Investment Advisers (“WTI”), however, that it is most efficient to hold the warrants and related equity securities at the Company level.  In the first instance, the opportunity to recognize value from the warrants and equity
      securities of Portfolio Companies may occur over many years, which is often longer than the term of the Fund.  Thus, shareholders benefit from the longer holding period available to the Company.  Second, over the lifecycle of the Fund, many of the
      loans made during the original investment period are paid off, resulting in overall lower assets for the Fund, while the equity of a small number of Portfolio Companies obtained through the exercise of warrants may continue to appreciate.  If all of
      the investments were held in the Fund, in the event of one or more material appreciations of a Portfolio Company, the fair value of the position could be so significant that later in the lifecycle of the Fund when a majority of the loans have been
      paid down such that there are minimal outstanding loan investments, the Fund may be unable to maintain its status  as a “regulated investment company” (“RIC”),  as it would not be able to meet the appropriate diversification requirements under
      Subchapter M.

    It should also be noted that the business development company (“BDC”) structure is beneficial because many of the beneficial shareholders of the Company are U.S. tax-exempt investors.  Any activities
      that could create “unrelated business taxable income” (“UBTI”) are blocked at the Fund level, because the Fund is a corporation for tax purposes.  As a RIC, all UBTI is blocked even though the RIC acts like a flow-through entity because of the
      dividends paid deduction.  All distributions to the Company are thus treated as dividends free of UBTI and Effectively Connected Income for tax purposes.  The structure thus benefits shareholders by allowing them to participate in returns from the
      Fund and to benefit from the longer equity investing horizon of the Company.

          2.

            Comment.  Statement of Operations, Disclosure of Realized Gains and Losses.  Please prospectively disclose any
                realized gains or losses arising from distributions in-kind of equity securities (including warrants) to shareholders.

          Mr. John Kernan

          November 13, 2024

          Page 3

    Response.

    As described in Item 1 of the Form 10-K under the sub-header, Equity Securities, the Fund anticipates that any warrants or equity securities obtained by the Fund will be simultaneously distributed to
      the Company at the time of their acquisition, or shortly thereafter. The warrants are fair valued at inception which establishes the cost basis.  The cost ascribed to the warrant generates an Original Issue Discount (OID) that is used to calculate
      the cost basis on the loan investment, as reflected in the Schedule of Investments.   The OID is then accreted into interest income over the life of the loan using the effective interest method.  To date, the Fund has distributed all warrants and
      equity securities to the Company immediately following their acquisition.  The warrants and equity securities are fair valued on the date of acquisition, and as a result, the Fund has not and does not expect to incur any gain or loss on the in-kind
      distributions made to the Company.

    The Form 10-K includes the following disclosure for Warrants and Equity Securities in Footnotes 1 and 2 of the Notes to Financial Statements:

    Footnote 1: “The Fund generally receives warrants to acquire equity securities in connection with its portfolio investments and generally distributes these warrants
        to its shareholder upon receipt, or soon thereafter.”

    Footnote 2: “Warrants and equity securities received in connection with loan transactions are measured at fair value at the time of acquisition.  Warrants are
        valued based on a Black-Scholes option pricing model which considers, among several factors, the underlying stock value, expected term, volatility, and risk-free interest rate.  It is anticipated that such securities will be distributed by the Fund
        to the Company simultaneously with, or shortly following, their acquisition.”

    The Form 10-K also includes the following disclosure within Footnote 3 – Fair Value Disclosures:

    “Interest is calculated using the effective interest method, and rates earned by the Fund will fluctuate based on many factors including early payoffs,
      volatility of values ascribed to warrants and new loans funded during the period. Warrants and equity securities received in connection with loan transactions are measured at fair value at the time of acquisition; the non-cash portion of interest
      income represents the accretion of the discount of these warrants over the life of the loan.”

          3.

            Comment.  Schedules of Investments.  Please explain, citing applicable U.S. GAAP, Reg. S-X, and other applicable accounting guidance, why
                  details of warrants and equities received in conjunction with loan investments are not disclosed in the Schedules of Investments, Statement of Assets and Liabilities and/or Statements of Operations.

    Response.

    The Fund has not and does not expect to incur any gains or losses on in-kind distributions made to the Company and therefore has historically not recorded any such items to the Statement of
      Operations.  As further described in the response to Comment #2 the Fund does not typically hold any warrant or equity positions as of the balance sheet date and therefore would not reflect them in the Schedule of Investments or Statement of Assets
      and Liabilities.  In the instance that we did hold any securities as of period-end, these would be reflected within the Schedule of Investments and other related financial statements.  Please refer to the response to Comment #5 for accounting
      treatment of warrants in relation to loan originations.

          Mr. John Kernan

          November 13, 2024

          Page 4

          4.

            Comment.  Schedules of Investments.  Please enhance descriptions of loans to provide details of the priority of lien (first or second) against
                  the pledged collateral, as this information will enable a reader to fully evaluate the risk associated with the investments.

    Response.

    The Fund believes that it has amply disclosed that all loans are secured by first-position liens and the related implications.  For example, the following disclosure is included in the Form 10-K,
      under Investment Program—Venture Loans:

    “Venture loans generally are made pursuant to a negotiated loan agreement and are evidenced by promissory notes secured by specific equipment or other assets of the borrower
      financed with the proceeds of such loans or secured by a broader lien on substantially all of the borrower’s assets where the purpose of the loan is to provide growth or general working capital to the borrower. The loans are typically secured by a
      first-position lien on such assets.”

    Additional disclosure is included under Investment Risks—Remedies Upon Default, as follows:

    “The Fund generally will require that it have a first priority security interest in any equipment of a borrower financed with the proceeds of the Fund’s loans,
        although that security interest may extend to the borrower’s other assets in which another lender might have a senior or parity security interest.”

    Further, the Schedule of Investments includes disclosure stating that every loan is currently in the “senior-secured” position for each Portfolio Company.  A “senior-secured” position equates to
      first position in terms of payout under any dissolution scenario, above equity holders and any other debt.  In the instance where we have multiple tranches of loans across multiple funds with the same Portfolio Company, we treat these pari-passu
      under the specific intercreditor agreement requirements that are issued alongside our co-investments.  Please refer to Footnote 7 of the notes to the Financial Statements – Intercreditor Agreements which states the following:

          Mr. John Kernan

          November 13, 2024

          Page 5

    “In all transactions in which the Fund and other funds managed by the Manager invest or those in which another lender(s) has either invested or may later invest (or in the event a
      successor fund is raised, in which the Fund and the successor fund invest), it is expected that the Fund and other funds managed by the Manager (or the successor fund as the case may be), and/or the other lender(s) will enter into an intercreditor
      agreement pursuant to which the Fund and other funds managed by the Manager (or the successor fund), and/or the other lender(s), along with any predecessor funds which still have a balance outstanding, will cooperate in pursuing their remedies
      following a default by the common borrower. Generally, under such intercreditor agreements, each party would agree that its security interest would be treated in parity with the security interest of the other party, regardless of which security
      interest would have priority under applicable law. Accordingly, proceeds realized from the sale of any collateral or the exercise of any other creditor’s rights will be allocated between the Fund and other funds managed by the Manager, and any
      predecessor funds as described above, pro rata in accordance with the amounts of their respective investments. An exception to the foregoing arrangement would occur in situations where, for example, one of the lenders financed specific items of
      equipment collateral; in that case, usually the lender who financed the specific assets will have a senior lien on that asset, and the other lenders will have a junior priority lien (even though they may ratably share liens of equal priority on other
      assets of the common borrower). As a result of such intercreditor agreements, the Fund may have less flexibility in pursuing its remedies following a default than it would have had had there been no intercreditor agreement, and the Fund may realize
      fewer proceeds. In addition, because the Fund and Fund IX (or the successor fund) invest at the same time in the same borrower, such borrower would be required to service two loans rather than one. Any additional administrative costs or burdens
      resulting therefrom may make the Fund a less attractive lender and may make it more difficult for the Fund to acquire such loans.”

          5.

            Comment.  Notes to Financial Statements - Summary of Significant Accounting Policies -  Investment
                  Valuation - Warrants.  Please expand on the significant accounting policy disclosures for warrants in the Notes to Financial Statements to clarify the unit of measurement, if the warrants are free-standing and detachable, how their
                  cost-basis is determined, how and where capital gains or losses are accounted for and disclosed, respectively, and finally, if the warrants are considered restricted under the Securities Act of 1933, as amended.

    Response.

    All of the Fund’s warrants are free-standing contracts that are legally detachable and separately exercisable following the guidance in ASC 815, and are considered restricted under the Securities Act
      of 1933, as amended. This is discussed in the Form 10-K under Item 1. Business – Investment Program, Warrants.  The unit of account is each individual warrant that represents a free-standing contract.  Please refer to our response to Comment #2 with
      respect to how the cost-basis of the warrants is determined and related gains/losses associated with in-kind distributions to the Company.

    Prospectively, the Fund will update the Notes to Financial Statements - Summary of Significant Accounting Policies -  Investment Valuation - Warrants and Equity Securities, as follows:

          Mr. John Kernan

          November 13, 2024

          Page 6

    “Warrants and equity securities received in connection with loan transactions are considered to be free
          standing contracts that are both legally detachable and separately exercisable from the related loan transactions and are measured at fair value at the time of acquisition. Warrants are valued based on a Black-Scholes option
      pricing model which considers, among several factors, the underlying stock value, expected term, volatility, and risk-free interest rate. It is anticipated that such securities will be distributed by the Fund to the Company simultaneously with, or
      shortly following, their acquisition.”

          6.

            Comment.  Notes to Financial Statements - Summary of Significant Accounting Policies – Investment Valuation - Non-Accrual Loans.  Please
                  evaluate the Fund's accounting policy for revenue recognition of non-accrual loa