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SEC Company Response from Partners Group Lending Fund, LLC (CIK 0001938649) — Dec 19, 2025

Partners Group Lending Fund, LLC (CIK 0001938649)
Date: Dec. 19, 2025 · CIK: 0001938649 · Accession: 0001398344-25-022749

AI Filing Summary & Sentiment

File numbers found in text: 000-56792

Date
December 19, 2025
Author
/s/ Darius I. Ravangard
Form
CORRESP
Company
Partners Group Lending Fund, LLC (CIK 0001938649)

Letter

VIA EDGAR Division of Investment Management Securities and Exchange Commission Washington, D.C. 20549-0504 Attn: Jeffrey W. Long Re: Partners Group Lending Fund, LLC Registration Statement on Form 10 (File No. 000-56792)

Dear Mr. Long:

On behalf of Partners Group Lending Fund, LLC, a Delaware limited liability company (the “Fund”), we hereby respond to the accounting comments you provided to me and Jessica Warshaw of Dechert LLP during a telephonic discussion on December 10, 2025 with respect to your review of the Fund’s registration statement of Form 10 (the “Registration Statement”), filed with the U.S. Securities and Exchange Commission (the “SEC”) on October 21, 2025. The Fund has considered your comments and has authorized us, on its behalf, to make the responses discussed below.

Set forth below are the comments of the SEC staff (the “Staff”) along with our responses thereto. To the extent not otherwise defined herein, capitalized terms have the meanings attributed to such terms in the Registration Statement.

1. Comment: In the “Incentive Fee” section on page 19 of the Registration Statement, please consider revising the disclosure to discuss only the Fund’s current investment advisory agreement (the Amended and Restated Investment Advisory Agreement).

Response: The Fund advises the Staff that it has revised such disclosure in the Fund’s amended Registration Statement filed herewith.

December 19, 2025

Page 2

2. Comment: The Staff notes that the Registration Statement includes financial statements for the period ended June 30, 2025. Please update the Registration Statement to include more recent financial statements.

Response: The Fund advises the Staff that it has revised such disclosure in the Fund’s amended Registration Statement filed herewith.

* * *

Should you have any questions regarding this letter, please contact me at (202) 261-3345 or Darius.Ravangard@dechert.com.

Sincerely,
/s/ Darius I. Ravangard

Show Raw Text
CORRESP
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filename1.htm

    1900 K Street, NW

    Washington, DC 20006-1110

    +1 202 261 3300 Main

    +1 202 261 3333 Fax

    www.dechert.com

    Darius I. Ravangard

    darius.ravangard@dechert.com

    +1 202 261 3345 Direct

December 19, 2025

VIA EDGAR

Division of Investment Management

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549-0504

Attn: Jeffrey W. Long

 Re: Partners Group Lending Fund, LLC

Registration Statement on Form 10 (File No. 000-56792)

Dear Mr. Long:

On behalf of Partners Group Lending
Fund, LLC, a Delaware limited liability company (the “Fund”), we hereby respond to the accounting comments you provided
to me and Jessica Warshaw of Dechert LLP during a telephonic discussion on December 10, 2025 with respect to your review of the Fund’s
registration statement of Form 10 (the “Registration Statement”), filed with the U.S. Securities and Exchange Commission
(the “SEC”) on October 21, 2025. The Fund has considered your comments and has authorized us, on its behalf, to make
the responses discussed below.

Set forth below are the comments
of the SEC staff (the “Staff”) along with our responses thereto. To the extent not otherwise defined herein, capitalized
terms have the meanings attributed to such terms in the Registration Statement.

 1. Comment: In the “Incentive Fee” section
on page 19 of the Registration Statement, please consider revising the disclosure to discuss only the Fund’s current investment
advisory agreement (the Amended and Restated Investment Advisory Agreement).

Response: The Fund advises
the Staff that it has revised such disclosure in the Fund’s amended Registration Statement filed herewith.

    December 19, 2025

    Page 2

 2. Comment: The Staff notes that the Registration Statement
includes financial statements for the period ended June 30, 2025. Please update the Registration Statement to include more recent financial
statements.

Response: The Fund advises
the Staff that it has revised such disclosure in the Fund’s amended Registration Statement filed herewith.

*        *        *

Should you have any questions
regarding this letter, please contact me at (202) 261-3345 or Darius.Ravangard@dechert.com.

    Sincerely,

    /s/ Darius I. Ravangard

    Darius I. Ravangard

      2