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   1900 K Street, NW

                                                                                Washington, DC 20006-1110

                                                                                +1 202 261 3300 Main

                                                                                +1 202 261
3333 Fax

                                                                                www.dechert.com

    Matthew J. Carter

    matthew.carter@dechert.com

                                                                                +1 202 261 3395 Direct

                                                                                +1 202 261 3333 Fax

January 30, 2024

Via Email

U.S. Securities and Exchange Commission

Division of Investment Management

100 F Street N.E.

Washington DC 20549

Attn: Mr. Michael A. Rosenberg

Re: LGAM Private Credit LLC

File Nos. 000-56619; 814-01674

Dear Mr. Rosenberg:

On behalf of LGAM Private Credit LLC (the “Company”
or “Fund”), this letter responds to comments issued by the staff (the “Staff”) of
the U.S. Securities and Exchange Commission (the “SEC”) in a letter dated December 26, 2023 relating to
the Fund’s registration statement on Form 10 that was filed with the SEC on December 1, 2023 (the “Registration
Statement”).

For your convenience, the Staff’s comments
are included in this letter, and each comment is followed by the responses of the Fund. Capitalized terms used in this letter and not
otherwise defined herein shall have the meanings specified in the Registration Statement.

ACCOUNTING COMMENTS

Item 1. Business (page 4)

 1. Comment: The fourth paragraph discloses that “our liquid loan portfolio could represent
a material portion of our investments from time to time”. Please explain whether the investments in this liquid loan portfolio would
be qualifying assets and how investing a material portion of investments in a liquid loan portfolio complies with Section 55(a) of
the Investment Company Act of 1940 (the “1940 Act”).

Response:
The Fund respectfully advises the Staff that while it generally expects a portion of its investments in its liquid loan portfolio to be
considered “qualifying assets” pursuant to Section 55(a)(6) of the 1940 Act, the Fund has processes in place to
confirm it will not acquire any assets (except as otherwise permitted pursuant to Section 55(a)) unless at the time of acquisition,
 “qualifying assets” held by the Fund represent at least 70% of the value of the Fund’s total assets in accordance with
Section 55(a) of the 1940 Act.

    January 30, 2024

    Page 2

Adviser (page 5)

 2. Comment: Please update the language in the second paragraph stating that you “intend
to enter into an investment advisory agreement with our Adviser prior to our election to be regulated as a BDC”, as the BDC election
has been filed. Please also update any similar disclosures throughout the Form 10.

Response:
The Fund undertakes to revise the disclosure accordingly in its future disclosures under the Exchange Act.

Warehouse Transaction (page 18)

 3. Comment: Please provide a Regulation S-X Article 12 compliant Schedule of Investments
as of a recent date that includes information on the investments to be acquired or the investments acquired if the conditions have been
satisfied. (Refer to IM Dear CFO Item 2023-02).

Response:
The Fund undertakes to revise the disclosure accordingly in an amendment to the Registration Statement or in the Fund’s annual report
on Form 10-K for the fiscal period ended December 31, 2023.

Investment Advisory Agreement (page 21-22)

 4. Comment: Please file the agreement obligating the Adviser to irrevocably waive the base
management and incentive fee on net investment income through March 31, 2024. Please disclose whether these waivers are subject to
recapture.

Response:
The Fund respectfully advises the Staff that the Adviser’s irrevocable waiver of the base management and incentive
fee on net investment income through March 31, 2024 has been disclosed in all material respects in the Registration Statement and
is not required to be filed pursuant to Item 601 of Form S-K because it was a unilateral waiver by the Adviser and the Fund is not
a party to the agreement. The Fund undertakes to revise the referenced disclosure to clarify that the Adviser’s waiver of base management
and incentive fees on net investment income through March 31, 2024 is not subject to recapture.

    January 30, 2024

    Page 3

 5. Comment: Please update the disclosure in the first paragraph on page 22 to match the
terms of Section 3(b)(1) of the Investment Advisory Agreement filed as EX-10.1 as it relates to the definition of “pre-incentive
fee net investment income”.

Response:
The Fund undertakes to revise the referenced disclosure as marked in bold in future SEC filings:

Pre-incentive fee net investment
income is defined as interest income, distribution income and any other income accrued during the calendar quarter, minus operating expenses
for the quarter, including the base management fee, expenses payable under the Administration Agreement and any interest expense and
distributions paid on any issued and outstanding preferred units, but excluding the incentive fee and any servicing fees and/or
distribution fees paid to broker dealers. Pre-incentive fee net investment income does not include any realized capital gains, realized
capital losses or unrealized capital appreciation or depreciation. Pre-incentive fee net investment income includes, in the case of
investments with a deferred interest feature (such as debt instruments with payment-in-kind (“PIK”) interest and zero coupon
securities), accrued income that the Company has not yet received in cash.

Qualifying Assets (page 31)

 6. Comment: Please verify the accuracy of the last statement in the last paragraph in this
section. The Investment Advisory Agreement does not appear to contain a clause excluding such transactions from the base management fee
calculation.

Response:
The Fund respectfully advises the Staff that any purchase of U.S. Treasury bills or other high-quality, short-term debt securities near
the end of the quarter would be considered a financing activity to satisfy certain regulated investment company diversification tests
for U.S. federal income tax purposes under Subchapter M of the Internal Revenue Code of 1986, as amended, and would not be expected to
impact the Fund’s net asset value for purposes of calculating the base management fee.

In addition, the
Fund undertakes to revise the disclosure as marked in bold in future SEC filings:

We may also purchase
U.S. Treasury bills or other high-quality, short-term debt securities at or near the end of the quarter and typically close out the position
on a net cash basis subsequent to quarter end. The Investment Advisory Agreement excludes the amount of these transactions
or such cash drawn for this purpose from total assets for purposes of computing the base management fee.

    January 30, 2024

    Page 4

Sarbanes-Oxley Act (page 33)

 7. Comment: Please verify the accuracy of the disclosure in the third bullet point in this
section considering the Fund’s emerging growth Fund status.

Response:
The Fund undertakes to revise the disclosure to remove reference to the requirement that the Fund’s independent registered public
accounting firm issue an audit report on the effectiveness of its internal control over financial reporting pursuant to Rule 13a-15
of the Exchange Act, because the Fund is eligible to rely on the exemption from this requirement for emerging growth companies under the
Jumpstart Our Business Startups Act of 2012, as amended.

Item 2. Financial Information Expense Support
Agreement (page 89-92)

 8. Comment: Please update the disclosure and the Expense Support Agreement to reflect that
no reimbursement payment will be made if the reimbursement payment causes the actual distribution rate in effect at the time of reimbursement
to be lower than the actual distribution rate in effect at the time the expense was initially paid/waived.

Response:
The Fund undertakes to update the disclosure and the Expense Support Agreement to reflect that no reimbursement will be made if the reimbursement
payment causes the distribution rate in effect at the time of reimbursement to be lower than the distribution rate at the time the expense
was initially paid by the Adviser.

 9. Comment: Please explain whether the full disclosure requirements of Item 305 of Regulation
S-K have been included. In your response, please explain the disclosure alternative selected and how the full disclosure requirements
have been met.

Response:
The Fund undertakes to revise its disclosures to include the sensitivity analysis referenced in Item 305(a)(1)(ii) and respectfully
submits that such analysis was not applicable as of the date of filing the Registration Statement as the Fund did not have investment
assets or liabilities as of such date.

Consolidated Statement of Financial Condition
(Page F-2)

 10. Comment: Please include the disclosure requirements of S-X 6-04.16-19. Also refer to Item
13 of Form 10 and S-X 6-01.

Response:
The Fund confirms that the consolidated statement of financial condition to be included in its Annual Report on Form 10-K for the
fiscal year ended December 31, 2023 will comply with the referenced disclosure requirements.

    January 30, 2024

    Page 5

 11. Comment: Please include a parenthetical reference next to the caption “Commitments
and Contingencies” referencing the specific Note to Financial Statements that addresses commitments and contingencies.

Response:
The Fund undertakes to revise the disclosure accordingly.

DISCLOSURE
COMMENTS

Explanatory Note (page 1)

 12. Comment: Please add the bulleted disclosure below, if applicable, in bold:

 · the amount of distributions that the Fund may pay, if any, is uncertain and the Fund may pay distributions
in significant part from sources that may not be available in the future and that are unrelated to the Fund’s performance (e.g.,
waiver of management and incentive fees).

 · the risks of capital being returned through distributions (e.g., that this may reduce an investor’s
adjusted tax basis in the Units, thereby increasing the investor’s potential taxable gain or reducing the potential taxable loss
on the sale of Units).

Response:
The Fund undertakes to revise the disclosure accordingly.

Item 1. Business (page 4)

 13. Comment: Please consider disclosing a fee table that conforms to the requirements of Item
3.1 of Form N-2 adjacent to this section. Please also consider disclosing an expense example that conforms to the requirements of
Instruction 11 to Item 3.1 of Form N-2. We further request that you consider including a second example where the five percent return
results entirely from net realized capital gains, with an introductory sentence of explanation of the second example. We believe that
such disclosure would be helpful to investors.

Response:
The Fund respectfully advises the Staff that it is not aware of any affirmative requirement to include a fee table that conforms to the
requirements of Item 3 of Form N-2 in a registration statement on Form 10. The Fund believes that such disclosure was omitted
from Form 10 for good reason, in that such disclosure would be inappropriate and potentially misleading for a Fund that is not undertaking
a public securities offering and remains at an early stage of development. The Fund respectfully advises the Staff that the disclosure
requirements of Item 3 of Form N-2 are intended to apply to a prospectus that is or will be used in connection with an offering of
securities by a registrant; the Registration Statement is not a prospectus, and any information included in the Registration Statement
and tending to suggest such an offering of securities could be construed as a general solicitation that would impede or void the Fund’s
ongoing private placement of Units.

    January 30, 2024

    Page 6

 14. Comment: The notes to the financial statements state that the Fund has formed wholly-owned
subsidiaries for the purpose of holding certain investments in portfolio companies made by the Fund. Accordingly, please include a section
under Item 1 that clarifies and discloses that the Fund has wholly-owned subsidiaries for the purpose of holding certain investments in
portfolio companies made by the Fund. With regard to any such subsidiary of the Fund, please disclose that:

 a. The Fund will comply with the provisions of the Act governing capital structure and leverage (Section 61)
on an aggregate basis with the subsidiary so that the Fund treats the subsidiary’s debt as its own.

Response:
The Fund respectfully advises the Staff that the current disclosure is accurate. For any subsidiary of the Fund that is wholly-owned,
the Fund will consider such subsidiary for purposes of the 1940 Act capital structure and leverage requirements.

 b. Any investment adviser to the subsidiary complies with provisions of the Act relating to investment advisory
contracts (Section 15) as if it were an investment adviser to the Fund under Section 2(a)(20) of the Act. Any investment advisory
agreement between the subsidiary and its investment adviser is a material contract that should be included as an exhibit to the Registration
Statement. If the same person is the adviser to both the Fund and the subsidiary, then, for purposes of complying with Section 15(c),
the reviews of the Fund’s and the subsidiary’s investment advisory agreements may be combined.

Response:
The Fund respectfully advises the Staff that any wholly owned subsidiaries of the Fund through which the Fund may engage in investment
activities are not expected to be parties to advisory or management contracts with either third-party or affiliated investment advisers,
including the Adviser. Rather, the Adviser will manage the investments held by such wholly owned subsidiaries of the Fund on a look through
basis pursuant to the Investment Advisory Agreement. The Fund does not currently intend to create or acquire primary control of any entity
that primarily engages in investment activities in securities or other assets, other than entities wholly owned by the Fund. While the
Fund itself may agree to serve as collateral manager for a wholly owned subsidiary formed for an on-balance sheet financing arrangement,
as is common among other BDCs, the Fund does not believe that any such collateral management agreement would fall within the scope of
Section 15 of the 1940 Act, as no such wholly owned subsidiary would itself be either a registered investment company or BDC under
the 1940 Act. The Fund further confirms to the Staff that it would generally expect to file any credit agreement pertaining to such financing
arrangements as an exhibit to its periodic reports required under the Exchange Act. Accordingly, the Fund respectfully declines to include
the requested disclosure. The Fund also respectfully refers the Staff to its below response to Comment No. 14(c) regarding wholly
owned subsidiaries being subject to the Fund’s compliance policies and procedures, including compliance with the applicable provisions
of the 1940 Act, and the Fund consolidating any such wholly owned subsidiaries for purposes of compliance with the 1940 Act.

    January 30, 2024

    Page 7

 c. The subsidiary complies with provisions relating to affiliated transactions and custody (Section 57).
Also, please identify the custodian of the subsidiary

Response:
The Fund respectfully advises the Staff that any wholly owned subsidiaries of the Fund would be subject to the Fund’s compliance
policies and procedures, including compliance with Section 57 of the 1940 Act, and the Fund would expect to consolidate any such
wholly owned subsidiaries for purposes of compliance with the 1940 Act. In addition, the Fund respectfully advises