SecProbe.io

CORRESP
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    1095 Avenue of the Americas

    New York, NY 10036-6797

    +1 212 698 3500 Main

    +1 212 698 3599 Fax

    www.dechert.com

    Richard Horowitz

    richard.horowitz@dechert.com

    +1 212 698 3525 Direct

    +1 212 698 0452 Fax

December 22, 2023

Michael A. Rosenberg

Attorney-Adviser

Division of Investment Management

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549-0504

 Re: Andalusian Credit Company, LLC

Registration Statement on Form 10

File Nos. 000-56604; 814-01670

Dear Mr. Rosenberg:

On behalf of Andalusian Credit
Company, LLC (the “Company”), this letter responds to the written comments issued by the staff of the Division of Investment
Management (the “Staff”) of the U.S. Securities and Exchange Commission (the “SEC”) in a letter dated November
22, 2023, as well as accounting comments delivered by the Staff verbally on December 5, 2023, in each case relating to the Company’s
registration statement on Form 10 that was filed with the SEC on October 30, 2023 (the “Registration Statement”).

For your convenience, the
Staff’s comments are included in this letter, and each comment is followed by the response of the Company. Capitalized terms used
in this letter and not otherwise defined herein shall have the meanings ascribed to them in Amendment No. 1 to the Registration Statement
filed by the Company on the date hereof (such registration statement being referred to herein as the “Amended Registration Statement”).

Summary of Risk Factors –
Page 3

1. Under the third bullet point, please briefly
state the specific risks associated with the use of leverage.

Response:
The Company has revised the disclosure on page 3 of the Amended Registration Statement in response to the Staff’s comment.

2. Under the fifth bullet point,
please state that below investment grade securities are predominantly speculative with respect to the issuer’s capacity to pay interest
and repay principal.

Response:
The Company has revised the disclosure on page 3 of the Amended Registration Statement in response to the Staff’s comment.

December 22, 2023

Page 2

Item 1. Business – Page 5

3. Please describe in plain English the meaning
of “club deals.”

Response:
The Company has revised the disclosure on page 5 of the Amended Registration Statement in response to the Staff’s comment.

4. Please supplementally explain what the affiliated
nature is between Andalusian Private Capital and the Adviser, and Andalusian Sports Advisors and the Adviser. For example, are the entities
under common control, is one a majority owned subsidiary of the other, etc.?

Response:
The Company notes to the Staff, on a supplemental basis, that the above-referenced entities are under common control by virtue of being
controlled by the same two principals. Neither Andalusian Private Capital and the Adviser, with respect to one another, nor Andalusian
Sports Advisors and the Adviser, with respect to one another, has a parent/subsidiary relationship.

5. Please supplementally explain whether the
Company and Andalusian Private Capital or Andalusian Sports Advisors have entered into any agreements related to the Company. If so, please
explain whether and why any such agreements constitute an advisory contract within the meaning of the 1940 Act.

Response:
The Company notes to the Staff, on a supplemental basis, that in connection with its obligations to the Company under the Advisory Agreement,
the Adviser has entered into an infrastructure sharing agreement with Andalusian Private Capital pursuant to which Andalusian Private
Capital has undertaken to share certain infrastructure resources, including Andalusian Private Capital’s premises, facilities, information
technology systems, computer hardware, software, and related administrative services (the “Infrastructure Sharing Agreement”).
The Company respectfully advises the Staff that the Infrastructure Sharing Agreement does not constitute an advisory agreement under the
1940 Act and that there are no advisory services being furnished to the Company through either Andalusian Private Capital or Andalusian
Sports Advisors. The Company also respectfully advises the Staff that the Adviser maintains its own separate investment personnel and
pursues a materially distinct strategy from both Andalusian Private Capital and Andalusian Sports Advisors.

Andalusian Sports Advisory has not entered
any agreements with the Adviser related to the Company.

6. Please explain: (i) specific services Andalusian
Private Capital and Andalusian Sports Advisors will provide to the Company and whether those services amount to advisory services provided
to the Company; (ii) the extent to which the Company will depend on Andalusian Private Capital or Andalusian Sports Advisors’ personnel
and resources for investment opportunities; (iii) whether the personnel who provide investment advice with respect to the Company will
be supervised persons of the Adviser under section 202(a)(25) of the Advisors Act; (iv) whether and what fees are paid to Andalusian Private
Capital and Andalusian Sports Advisors and whether they are paid pursuant to an agreement; and (v) whether the Andalusian Private Capital
and Andalusian Sports Advisors are considered fiduciaries with respect to the Company.

December 22, 2023

Page 3

Response:
The Company respectfully refers the Staff to the Company’s response to Comment #5 of this letter with respect to clauses (i) and
(ii) of this Comment #6 and notes that neither Andalusian Private Capital nor Andalusian Sports Advisors provides any services directly
to the Company.

With respect
to clause (iii) of this Comment #6, the Company respectfully advises the Staff, on a supplemental basis, that all personnel who will provide
investment advice with respect to the Company will be supervised persons of the Adviser under Section 202(a)(25) under the Advisers Act.

With respect
to clause (iv) of this Comment #6, the Company respectfully advises the Staff, on a supplemental basis, that the Company pays no fees
to either Andalusian Private Capital or Andalusian Sports Advisors.

With respect
to clause (v) of this Comment #6, the Company respectfully advises the Staff, on a supplemental basis, that neither Andalusian Private
Capital nor Andalusian Sports Advisors is considered a fiduciary with respect to the Company.

The Private Offering – Page
6

7. Please confirm whether the Initial Closing
Date is expected to occur in 2023 or 2024.

Response:
The Company respectfully advises the Staff that the Initial Closing Date occurred on November 14, 2023. The Company has revised the disclosure
on page 7 of the Amended Registration Statement accordingly.

Liquidity Event – Page 7

8. Please provide additional detail
about what factors could impact the Company’s ability to consummate a Liquidity Event.

Response:
The Company has revised the disclosure on page 7 of the Amended Registration Statement in response to the Staff’s comment.

Competitive Strengths – Maintaining Portfolio Diversification
 – Page 9

9. Please reconcile this
disclosure with later disclosure stating that unfavorable performance by a small number of portfolio companies could adversely affect
the aggregate returns realized by the Members, and that the number of portfolio holdings may be insufficient to afford adequate diversification
against the risk that an insufficient number of portfolio companies in which the Company invests may yield a return.

Response:
The Company has revised the disclosure on page 10 of the Amended Registration Statement in response to the Staff’s comment.

December 22, 2023

Page 4

Investment Objectives –
Page 8

10. Please clarify in the disclosure how the
Company is defining indirect investments in credit obligations and related instruments.

Response:
The Company has revised the disclosure on page 8 of the Amended Registration Statement in response to the Staff’s comment.

11. The disclosure states that “[t]he
Company defines “credit obligations and related instruments” for this purpose...and other instruments that provide exposure
to such fixed income instruments.” Please disclose how the Company is defining “other instruments”.

Response:
The Company has revised the disclosure on page 8 of the Amended Registration Statement in response to the Staff’s comment.

Investment Process Overview –
Underwriting – Page 10

12. State that the number of portfolio companies
in which the Company invests may be insufficient to afford adequate diversification against the risk that an insufficient number of portfolio
companies in which the Company invests may yield a return.

Response:
The Company has revised the disclosure on page 11 of the Amended Registration Statement in response to the Staff’s comment.

13. Provide an overview of ACP’s ESG
policy and disclose whether investments can be made in a company that has unfavorable ESG characteristics.

Response: The
Company has revised the disclosure on page 11 of the Amended Registration Statement in response to the Staff’s comment.

Investment Structure –
Equity Investments – Page 13

14. Please revise this paragraph
to reflect that the Company’s ability to engage in co-investments with affiliates is limited and/or prohibited by Section 57 of
the Investment Company Act of 1940.

Response:
The Company has revised the disclosure on page 15 of the Amended Registration Statement in response to the Staff’s comment.

December 22, 2023

Page 5

Management Fees – Page 16

15. Please include a fee table in this section
that conforms to the requirements of Item 3.1 of Form N-2.

Response:
The Company respectfully submits that the instructions to Form 10 do not require the inclusion
of the above-referenced fee table and thus the Company respectfully declines to include a fee table.

Incentive Compensation – Page 16

16. Please provide a graphical
representation of the income-related portion of the incentive fee, and examples demonstrating the operation of the incentive fee.

Response:
The Company respectfully advises the Staff that examples demonstrating the operation of the incentive fee are not required by the instructions
to Form 10. The purpose of the Company’s Form 10 registration statement is to register the Shares under the Securities Exchange
Act of 1934, as amended (the “Exchange Act”). The Form 10 is not an offering disclosure document, and it does not require
the inclusion of the incentive fee examples.

The Company
also respectfully declines to add the requested graphic because it believes that information included in the bullets under the section
titled “Income-Based Incentive Fee” on pages 17 and 18 of the Amended Registration Statement is useful to investors and
provides concrete examples of the operation of the Income Incentive Fee.

17. Describe the conflicts of interest associated
with making investments or using techniques, such as leverage, that have the effect of increasing the Adviser’s compensation.

Response:
The Company has revised the disclosure on page 40 of the Amended Registration Statement in response to the Staff’s comment.

Capital Gains Incentive Fee
 – Page 18

18. Please supplementally explain whether the
20% incentive fee will not exceed 20% of the Company’s realized capital gains net of all realized capital losses and unrealized
capital depreciation.

Response:
The Company respectfully advises the Staff, on a supplemental basis, that the Capital Gains Incentive Fee will not exceed 20% of the Company’s
cumulative aggregate realized capital gains less cumulative aggregate realized capital losses and aggregate unrealized capital depreciation.

Payment of the Company’s
Expenses – Page 19

19. Disclosure on page
19 refers to the formation of subsidiary investment vehicles. Please respond to the following comments regarding any primarily controlled
entity that engages in investment activities in securities or other assets. A primarily controlled entity is an entity that the Company
controls as defined in Section 2(a)(9) of the 1940 Act and for which the Company’s control of the entity is greater than that of
any other person.

December 22, 2023

Page 6

a.	Disclose
any of the subsidiary’s principal investment strategies or principal risks that constitute principal investment strategies or principal
risks of the Company.

Response:
The Company respectfully advises the Staff that the Company does not currently have any such subsidiary investment vehicles. However,
the Company confirms to the Staff that any principal strategies or risks of a subsidiary vehicle that constitute principal strategies
or risks of the Company will be disclosed to investors.

b.	Disclose
that the Company complies with the provisions of the 1940 Act governing capital structure and leverage (Section 18, as modified by Section
61) on an aggregate basis with the subsidiary.

Response:
In light of the fact that the Company does not currently have any such subsidiaries, the Company believes the current disclosure is sufficient
and respectfully declines to revise the disclosure. To the extent that the Company establishes subsidiary investment vehicles, the Company
confirms to the Staff, on a supplemental basis, that the Company will comply with the provisions of the 1940 Act governing capital structure
and leverage (Section 18, as modified by Section 61) on an aggregate basis with such subsidiaries.

c.	Disclose
that each investment adviser to the subsidiary complies with the provisions of the 1940 Act relating to investment advisory contracts
(Section 15 as it applies through Section 59) as an investment adviser to the Company under Section 2(a)(20) of the 1940 Act. Also file
the investment advisory agreement between the subsidiary and its investment adviser as an exhibit to the registration statement. See Item
25.2.k. of Form N-2.

Response:
In light of the fact that the Company does not currently have any such subsidiaries, the Company believes the current disclosure is sufficient
and respectfully declines to revise the disclosure. The Company confirms to the Staff, on a supplemental basis, that the Advisory Agreement
contemplates that the Adviser may provide its advisory services to the Company through subsidiaries or special purpose vehicles, so the
Company does not currently expect for an additional advisory agreement to be entered into with respect to any such subsidiary or vehicle.

d.	Disclose
that each subsidiary complies with the provisions relating to affiliated transactions and custody (Section 17 as modified by Section 57).
Identify the custodian of the subsidiary.

Response:
In light of the fact that the Company does not currently have any such subsidiaries, the Company believes the current disclosure is sufficient
and respectfully declines to revise the disclosure. To the extent that the Company establishes subsidiary investment vehicles, the Company
expects that each such subsidiary will comply with the 1940 Act provisions related to affiliated transactions and custody (Section 17,
as modified by Section 57). The Company has revised the disclosure on page 20 of the Amended Registration Statement to state that it
expects that any such subsidiary would use the same custodian as the Company.

e.	Confirm
to us that the financial statements of each subsidiary will be consolidated, as applicable, with those of the Company in accordance with
U.S. Generally Accepted Accounting Principles, Regulation S-X and other applicable accounting guidance.

Response:
The Company respectfully advises the Staff that it expects that the financial statements of its wholly owned or substantially wholly owned
subsidiaries will be consolidated with the Company’s financial statements in accordance with U.S. Generally Accepted Accounting
Principles, Regulation S-X and other applicable accounting guidance.

December 22, 2023

Page 7

 f.	Confirm
to us that (a) if a subsidiary is not organized in the U.S., the subsidiary and its board of