SecProbe.io

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November 9, 2023

VIA EDGAR

U.S. Securities and Exchange Commission

Division of Investment Management

100 F Street, NE

Washington, D.C. 20549

Attention: Yoon Choo

 Re: Meketa Infrastructure Fund (File Nos. 811-23899; 333-274323)

Dear Ms. Choo:

On behalf of Meketa Infrastructure Fund (the
“Fund”), we are writing to respond to comments of the staff (the “Staff”) of the U.S. Securities and Exchange
Commission (the “Commission”) that you provided via e-mail on October 2, 2023 in connection with the Fund’s registration
statement relating to the common shares of beneficial interest of the Fund, which was filed with the Commission on September 1, 2023 (SEC
Accession No. 0001580642-23-004656) (the “Registration Statement”). Capitalized terms not defined herein have the meaning
given to them in the Registration Statement.

The following sets forth the Staff’s
comments and the Fund’s responses thereto. We note that the responses set forth herein, as applicable, will be observed by the Fund
but do not necessarily represent the position or policy of other funds advised or sub-advised by Meketa Capital, LLC (“Meketa Capital”
or the “Adviser”) or its affiliates. The below responses will be reflected, to the extent applicable, in the form of a pre-effective
amendment to the Registration Statement.

GENERAL

 1. Staff Comment: We note that the Registration Statement is missing information and exhibits (e.g.,
information on trustees of the Fund, seed financial statements of the Fund, etc.…) and contains bracketed disclosures. We may have
comments on such portions when you complete them in any pre-effective amendment, on disclosures made in response to this letter, on information
supplied supplementally, or on exhibits filed in any pre-effective amendment. Please plan accordingly.

Response: The
Fund confirms that these items will be submitted in a subsequent amendment to the Registration Statement and acknowledges it is aware
the Staff may have additional comments once it has reviewed these items.

 2. Staff Comment: Where a comment is made regarding disclosure in one location, it is applicable to
all similar disclosure appearing elsewhere in the Registration Statement. Please make all conforming changes.

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Response: In
cases where the Fund undertakes to revise disclosure in response to a comment from the Staff, the Fund will make conforming changes to
similar disclosure appearing elsewhere in the Registration Statement to the extent applicable.

 3. Staff Comment: The Fund discloses that it may employ leverage. Please inform us whether the Fund
intends to issue preferred stock or debt securities within a year from the effective date of the Registration Statement.

Response: The
Fund does not intend to issue preferred stock or debt securities within a year from the effective date of the Registration Statement.

 4. Staff Comment: The Fund has filed an application for exemptive relief from various portions of
the 1940 Act and rules thereunder to permit the Fund to issue multiple classes of shares and to impose early withdrawal charges and asset-based
distribution and/or service fees (the “Exemptive Application”). The last paragraph under Statement of Fact in
the Exemptive Application states that the Fund may offer an exchange feature under which shareholders may, in connection with the Fund’s
periodic repurchase offers, exchange their Shares for shares of the same class of (i) registered open-end investment companies, or (ii)
other interval funds that are in the Fund’s group of investment companies. This feature is not discussed in the Registration Statement.
Please advise us as to the Fund’s plans with respect to this exchange feature.

Response: The
referenced disclosure in the Exemptive Application is identical to exemptive applications recently granted by the Commission for multiple
share class relief and was included in reliance on Rule 0-5 under the Investment Company Act of 1940, as amended (the “1940 Act”),
in connection with the Fund’s request for expedited review. The Fund does not currently intend to implement such an exchange feature
for its shares.

 5. Staff Comment: Please advise us if you expect to submit any other exemptive application(s) or any
no action request(s) in connection with the Registration Statement.

Response: The
Fund does not currently intend to submit another exemptive application or a no-action request in connection with the Registration Statement.

 6. Staff Comment: Please tell us if you have presented or will present any “test the waters”
materials to potential investors in connection with this offering. If so, please provide us with copies of such materials.

Response: The
Fund has not and does not intend to present any “test the waters” materials to potential investors in connection with this
offering.

FACING PAGE

 7. Staff Comment: Section 8(c) of the 1933 Act relates to amendments filed after the effective date
of a registration statement. Please uncheck the box next to “when declared effective pursuant to Section 8(c) …”

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Response: The
Fund will uncheck the box on the facing page referenced above in its next pre-effective amendment the Registration Statement.

PROSPECTUS

Cover Page

 8. Staff Comment: Please address the following comments related to the Fund’s investment strategy
discussion:

a. The list of
investments in clause (iv) is long and difficult to follow. Please confirm to us that the investments listed in this section are all principal
investments of the Fund or revise to identify only those instruments that are part of the Fund’s principal investment strategy.
Please ensure that an investor can clearly understand any revised list of investments;

b. Clause (iv)
includes as investments, “vehicles whose primary purpose is to... provide services to privately held infrastructure companies, quasi-governmental
infrastructure entities, public-private partnerships, and/or public infrastructure owners and operators.” The term “provide
services to” is quite broad. Please revise to clarify what types of investments are covered by this component that are not covered
by the remainder of the clause; and

c. “Infrastructure
assets” is defined to include “other products and services required for the normal function of society.” This category
is quite broad and could encompass investments that an investor would not typically view as infrastructure related. Please revise to narrow
this category so that it is significantly tied to infrastructure assets.

Response:

 a. The Fund has revised its disclosure as marked below.

(iv)
individual publicly listed companies that pursue the business of private infrastructure investing vehicles
including special purpose acquisition companies (“SPACs”), investment funds, and individual companies, utilities, and
master limited partnerships that pursue the business of infrastructure ownership, operations, and/or investing, including listed
mutual funds and exchange traded funds holding multiple listed infrastructure stocks, listed infrastructure funds and funds-of-funds,
special purpose acquisition companies (“SPACs”), asset managers, holding companies, investment trusts, closed-end funds, financial
institutions, and other vehicles whose primary purpose is to own and operate, invest in, lend capital to, or provide services to privately
held infrastructure companies, quasi-governmental infrastructure entities, public-private partnerships, and/or public infrastructure owners
and operators (“Public

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Infrastructure Investments,”
together with Portfolio Companies, Infrastructure Credit Instruments, and Portfolio Funds, “Infrastructure Investments”).

 b. The Fund has revised its disclosure as marked above in response to Comment 8a.

 c. The Fund has revised its disclosure to state as follows.

The Fund defines
“infrastructure assets” as assets that primarily comprise physical facilities, buildings, systems, and networks, and their
associated operations in sectors and industries including energy, power, communication, transportation, social (e.g., education, hospitals,
judicial buildings, etc.), water, and waste.

 9. Staff Comment: Footnote 2 to the fee table states that the Fund will charge a 2.00% early repurchase
fee for the repurchase of Shares held for less than one year. Given the SEC has not yet granted the relief requested in the Exemptive
Application that would permit the imposition of such fee, please revise disclosure throughout the Registration Statement to clarify the
fee may only be charged if the relief is granted.

Response: The
Fund respectfully notes that Rule 23c-3 under the 1940 Act, which governs repurchase offers by interval funds, permits the imposition
of a repurchase fee. Specifically, Rule 23c-3 states that a fund “may deduct from the repurchase proceeds only a repurchase fee,
not to exceed two percent of the proceeds, that is paid to the [fund] and is reasonably intended to compensate the company for expenses
directly related to the repurchase.” The Fund is therefore not required to rely upon any exemptive relief for the imposition of
an early repurchase fee in accordance with Rule 23c-3. Accordingly, the Fund does not believe it is necessary to revise the disclosure.

 10. Staff Comment: Here and under Summary — Quarterly Repurchase Offers, please disclose
the interval between the date on which the Fund’s NAV applicable to a repurchase offer is calculated and the date of repayment.
(See Guide 10).

Response: The
Fund has added the following disclosure under Summary — Quarterly Repurchase Offers.

The Fund expects
to distribute payment to Shareholders between one (1) and three (3) business days after the Repurchase Pricing Date and will distribute
such payment no later than seven (7) calendar days after such date.

 11. Staff Comment: The disclosure states that “[i]n the event that the Fund encounters delays
in locating suitable investment opportunities, all or a substantial portion of the distributions made to [shareholders] by the Fund may
constitute a return of your capital …” Please reconcile this statement, which appears in a number of places throughout the
Prospectus, with the disclosure under Use of Proceeds that “[i]t is currently anticipated that the Fund will be able to invest
all or substantially all of the net proceeds in accordance with its

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investment objective and strategies as
soon as practicable after receipt of the proceeds, first in more liquid publicly traded securities and short-term investments, then in
privately offered securities (including Portfolio Companies and Portfolio Funds) as they become available to the Fund …”
Please explain in an appropriate location in the Prospectus why the Fund would return capital when it does not promise any fixed amount
or frequency of distributions and when it may invest in liquid publicly traded securities in the interim.

Response: The
Fund has removed the first referenced disclosure.

 12. Staff Comment: Please remove “generally” from the second bullet point.

Response: The
Fund has removed the requested disclosure.

 Summary

The Fund

 13. Staff Comment: In the second paragraph, please disclose which class of Shares are currently being
offered by the Prospectus. Also, please ensure that each discussion of the Exemptive Application is accompanied by a statement that there
is no assurance that the SEC will grant the relief requested in the Exemptive Application.

Response: The
Fund has added the requested disclosure.

Investment
Objectives and Strategies

 14. Staff Comment: The Fund has adopted a names policy per Rule 35d-1. Please disclose in an appropriate
location in the Prospectus that shareholders will be given 60 days advance written notice of a change to the names policy, and the Fund
will consider the investments of the Portfolio Funds in which it invests when determining compliance with its names policy.

Response: The
Fund has added “[t]he Fund will provide shareholders with at least 60 days’ prior notice of any change in this 80% policy”
to the first paragraph under Investment Objective and Strategies – Investment strategies in the prospectus. The Fund respectfully
declines to add disclosure that it will consider the investments of the Portfolio Funds in which it invests for the purposes of determining
compliance with its names policy. In the recent release adopting amendments to Rule 35d-1 under the 1940 Act, the Commission stated that
“it would generally be reasonable for a fund of funds or other acquiring fund to include the entire value of its investment in an
appropriate acquired fund when calculating compliance with the 80% investment requirement without looking through to the acquired fund’s
underlying investments.” The Commission provides as an example that “a fund of funds with the name ‘XYZ Industrials
Fund’ with an 80% investment policy to invest in the industrials sector could count the entire value of its investments in the ‘ABC
Automotive Fund’ when calculating compliance with the 80% investment requirement, provided that the ABC Automotive Fund has an 80%
investment policy to invest in its subsection of the industrials sector.” The Portfolio Funds are not required to comply with

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Rule 35d-1 and therefore may not have
formally adopted such an 80% policy. Nevertheless, the Fund believes that investing in Portfolio Funds with this investment focus is consistent
with the Fund’s own names policy and, to the extent the Fund knows that a Portfolio Fund is not investing consistent with the Fund’s
investment focus, the Fund will endevour to look through to such Portfolio Fund’s underlying investments or exclude its investment
in such Portfolio Fund when determining compliance with its names policy.

 15. Staff Comment: The Fund may invest in Portfolio Companies indirectly through SPVs. Please provide
a brief description (with a more detailed description later in the Prospectus) of how these investments will be structured. If the SPVs
are expected to be wholly-owned or primarily controlled by the Fund (i.e., the Fund controls the unregistered entity within the
meaning of Section 2(a)(9) of the 1940 Act, and the Fund’s control of the unregistered entity is greater than that of any other
person), please also address the following comments:

a. Disclose any of
the SPV’s principal investment strategies or principal risks that constitute principal investment strategies or principal risks
of the Fund;

b. Disclose that
the Fund complies with the provisions of the 1940 Act governing investment policies (Section 8) and capital structure and leverage (Section
18) on an aggregate basis with the SPV;

c. Disclose that
each investment adviser to the SPV complies with the provisions of the 1940 Act relating to investment advisory contracts (Section 15)
as an investment adviser to the Fund under Section 2(a)(20) of the 1940 Act. Please also file the investment advisory agreement between
the SPV and its investment adviser as an exhibit to the registration statement. (See Item 25.2.k.);

d. Disclose that
each SPV complies with the provisions relating to affiliated transactions and custody (Section 17). Identify the custodian of the SPV;

e. Confirm to
us that the financial statements of each wholly-owned SPV will be consolidated with those of the Fund; and

f. Confirm to us that
(1) a SPV’s management fee (including any performance fee) will be included in the “Management Fee” line item of the
fee table and an SPV’s expenses will be included in the “Other Expenses” line item of the fee table; (2) if any SPV
is not organized in the U.S., the SPV and its board of directors/trustees will agree to designate an agent for service of process in the
U.S.; and (3) a SPV and its board of directors/trustees will agree to inspection by the staff of the SPV’s books and records, which
will be maintained in accordance with Section 31 of the 1940 Act.

Response: The
Fund has revised and added the follow