SecProbe.io

August 20, 2024
Tom Berry
Chief Executive Officer
ILS Fixed Horizon LLC
PO Box 1227
210 Market Street
El Campo, TX 77437
Re:ILS Fixed Horizon LLC
Amendment No. 7 to Offering Statement on Form 1-A
Filed June 4, 2024
File No. 024-12055
Dear Tom Berry:
            We have reviewed your amended offering statement and have the following comments.
            Please respond to this letter by amending your offering statement and providing the
requested information. If you do not believe a comment applies to your facts and circumstances
or do not believe an amendment is appropriate, please tell us why in your response.
            After reviewing any amendment to your offering statement and the information you
provide in response to this letter, we may have additional comments. Unless we note otherwise,
any references to prior comments are to comments in our May 12, 2024 letter.
Amended Offering Statement on Form 1-A
Cover Page
1.Please revise the risk factors on your cover page to address the risk that the Debt Units
holders may not be able to withdraw the Debt Unit funds from the company and that the
Debt Units are illiquid investments since no market exists for the Debt Units. Also revise
your Risk Factors section, on page 21, to clearly address the risk that Debt Units holders
might not be able to withdraw the Debt Unit funds from the company.
Offering Circular Summary, page 13
We note your response to prior comment 2 regarding early withdrawals.  Please revise
your disclosure to include the substance of your response to that comment including
that the discretionary withdrawal option is intended to serve as a very occasional
occurrence, if and when a particular investor requests it, traditionally for personal 2.

August 20, 2024
Page 2
reasons, that investors generally need to provide a compelling reason for their withdrawal
requests, that you do not anticipate many such occurrences, that investors would be
redeemed at the same price per unit at which they initially invested, which is priced at
$1,000 per unit and that there is no premium on these units.
Roll-Over Mechanism of Units in all Classes, page 16
3.You propose to issue additional debt securities to your holders by offering to reinvest the
accrued interest otherwise due on their securities on a monthly basis and that these
additional purchases will count towards your total offering amount.  Please revise to
clarify how your activities will be done in compliance with Regulation A, for example,
please ensure that your analysis and disclosure reflects: (i) that you will obtain the
affirmative consent from each holder prior to any and each subsequent investment in your
debt securities made with such holder’s accrued interest amounts; (ii) confirm that you
will provide investors with a hyperlink to the current offering circular in connection with
and at the time of any such additional monthly investment (refer to Rule 251(d)(1)(iii));
(iii) how you will comply with the investment limitations and qualifications for purchaser
status set forth in Rule 251(d)(2)(i)(C) with respect to monthly investments made with
accrued interest amounts; and (iv) how you will ensure you are eligible to offer and sell
securities pursuant to Regulation A at the time of such sales.
Use of Proceeds, page 30
4.We note that you have removed the use of proceeds at a 50% of the maximum offering
from the Use of Proceeds table. Please revise to indicate the use of proceeds at the 50% of
the maximum offering amount in the Use of Proceeds table.
Beneficial Ownership of Company, page 44
5.We reissue prior comment 4 in part. Please include the listing of all executive officers as a
group in the table, as a separate line.  Refer to Item 12(a)(1) of Part II of Form 1-A.
            Please contact Ruairi Regan at 202-551-3269 or David Link at 202-551-3356 with any
other questions.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction
cc:Larry Pino, Esq.