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CORRESP

 Simpson Thacher & Bartlett LLP

425 LEXINGTON AVENUE

NEW YORK, NY 10017-3954

TELEPHONE:
+1-212-455-2000

FACSIMILE:
+1-212-455-2502

 VIA EDGAR

 April 25, 2025

Re:
 EQT Infrastructure Company LLC

Post-Effective Amendment No. 1 to Registration Statement on Form 10-12G

Filed December 19, 2024

File No. 000-56691

Securities and Exchange Commission

 Division of Corporation
Finance

 100 F Street, N.E.

 Washington, D.C. 20549

Ladies and Gentlemen:

 On behalf of EQT
Infrastructure Company LLC (the “Company”), we are concurrently filing with the Securities and Exchange Commission (the “Commission”) a second post-effective amendment (“Post-Effective Amendment No. 2”) to the
above-referenced registration statement on Form 10-12G (the “Registration Statement”), originally filed with the Commission on September 20, 2024. The Company has revised the Registration
Statement in response to the comment letter from the staff (the “Staff”) of the Commission’s Division of Corporation Finance, dated February 11, 2025 (the “Comment Letter”), relating to the Registration Statement and to
reflect certain other changes.

 In addition, we are providing the following responses to the Comment Letter. To assist your review, we
have retyped the text of the Staff’s comments in italics below. Page references in the text of this letter correspond to the pages of Post-Effective Amendment No. 2. Unless otherwise defined below, terms defined in Post-Effective Amendment
No. 2 and used below shall have the meanings given to them in Post-Effective Amendment No. 2. The responses and information described below are based upon information provided to us by the Company.

Post Effective Amendment No. 1 to Form 10

Exhibits

1.
 Comment: We note your response to prior comment 3. Please revise the Form of Share Repurchase Plan
filed as Exhibit 4.3 to reflect your revised disclosure that you will extend the repurchase date so that at least 10 business days would remain from the announcement of the transaction price for the applicable quarter if you extend the repurchase
offer to a later date.

Securities and Exchange Commission

 2

April 25, 2025

 Response: In response to the Staff’s comment, the Company has revised the Form of
Share Repurchase Plan filed as Exhibit 4.3 to Post-Effective Amendment No. 2.

 General

2. Comment: We note your response to prior comment 5 and your discussion of the Fifth Avenue opinion. You suggest that the district court’s
reading is “problematic” because “any issuer owning and holding securities issued by a majority-owned subsidiary...would nonetheless be captured as an investment company under 3(a)(1)(A).” It does not appear to the staff that the
district court’s reading would oblige such a result, given the facts and circumstances nature of analysis under Section 3(a)(1)(A) (and 3(a)(1)(A)’s lack of a requirement for unconsolidated analysis); assuming an issuer is a bona fide
holding company engaging in the business of its operating majority owned subsidiary, it would appear that the majority owned subsidiary’s business—including, for example, its income, assets, etc.—would be considered in evaluating the
parent’s primary business. Nevertheless, even to the extent one were to accept the view advanced in your response, please discuss whether the fact that (i) you (and affiliates of any particular Control JV) will be buying (and selling)
securities on an ongoing basis and (ii) you expect the majority of Control JVs to sell their interests in portfolio companies within three to five years complicates any conclusion that a Control JV is merely “holding” securities. In
your response, please clarify at what level of activity you believe a Control JV would be “investing” rather than “holding.”

Response:

 You previously asked us to address the
following language from the district court’s opinion in Fifth Avenue:

“Strangely enough, in [the Investment Company Act] concerned entirely with the subject of investments,
Section 2(a), which defines 42 different terms, does not define the word ‘invest.’ That word must be given its normal meaning, i.e., to put out money at risk in the hope of gain. It would not be reasonable to construe the word for the
purposes of Section [3(a)(1)(A)] to include one kind of gain but not another. The [Investment Company Act] should not be read to mean that buying a stock for dividends or for capital gain is investing but that buying it for control is not. Those who
seek control obviously do so in the hope of ultimate gain.”1

In our December 19th Letter, we explained our view that the district court’s view is untenable
because it would effectively capture every holding company under Section 3(a)(1)(A),2 which seemingly conflicts with Congress’s intent as evidenced by Section 3(a)(1)(C)’s
references “investment securities” and Section 3(a)(2)’s carveout of majority-owned subsidiaries from the definition of “investment securities.”3

1
 SEC v. Fifth Ave. Coach Lines, Inc., 289 F. Supp. 3, 30 (S.D.N.Y. 1968).

2
 Unless otherwise stated, all references to sections or rules herein refer to those sections or rules as
promulgated under the Investment Company Act of 1940, as amended (the “Investment Company Act”).

3
 See also infra note 89.

Securities and Exchange Commission

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April 25, 2025

 We note the Staff’s view that using the district court’s reasoning with respect to
Section 3(a)(1)(A) would not dictate that result because Section 3(a)(1)(A) may be tested on a consolidated basis. In that respect, we note that while Section 3(a)(1)(A) does not specify that it must be run on unconsolidated basis, as
Section 3(a)(1)(C) does, Section 3(a)(1)(A) also does not specify any consideration of subsidiaries, whether they be wholly owned, majority-owned, controlled or otherwise.4 This is in
contrast to Section 3(b)(2) which focuses on the largely the same question but specifically allows for consideration of activities done indirectly through certain subsidiaries.5 While we
generally believe applying Section 3(a)(1)(A)’s tests on a consolidated basis is the most logical approach in most instances (including because the courts have held that what principally matters under Tonopah is “investor
perception”6 and an issuer’s financial statements are generally presented to its investors on a consolidated basis under GAAP), we also believe a reading of the statute that gives effect
to differences between 3(a)(1)(A) and other sections such as 3(b)(2) can reasonably suggest that the test of Section 3(a)(1)(A) is specific to each issuer individually, and not to each issuer and its majority-owned subsidiaries.

Finally, we would note that Section 3(a)(1)(A) also gives effect to an issuer’s statements and representations. The district court reasoned that
“[t]he [Investment Company Act] should not be read to mean that buying a stock for dividends or for capital gain is investing but that buying it for control is not.”7 Under this
framework, it appears to us that if a bona fide holding company were to accurately acknowledge to its investors that “the holding company’s only asset is its interests in its wholly owned subsidiaries,” then such a holding
company would now be “holding itself out” as being primarily engaged in the business of “investing . . . in securities.” This does not appear to us to be consistent with either Congressional intent or past Staff positions.8

•

 Nevertheless, even to the extent one were to accept the view advanced in your response, please discuss whether
the fact that (i) you (and affiliates of any particular Control JV) will be buying (and selling) securities on an ongoing basis and (ii) you expect the majority of Control JVs to sell their interests in
portfolio companies within three to five years complicates any conclusion that a Control JV is merely “holding” securities. In your response, please clarify at what level of activity you believe a Control JV would be “investing”
rather than “holding.”

4
 Section 3(a)(1)(A) captures, in relevant part: “Any issuer which is or holds itself out as being
engaged primarily, or proposes to engage primarily, in the business of investing, reinvesting, or trading in securities.”

5
 Section 3(b)(2) excludes, in relevant part: “Any issuer . . . primarily engaged in a business or
businesses other than that of investing, reinvesting, owning, holding, or trading in securities either directly or (A) through majority-owned subsidiaries or (B) through controlled companies conducting similar types of businesses.”

6
 SEC v. Nat’l Presto Indus., 486 F.3d 305, 313 (7th Cir. 2007).

7
 SEC v. Fifth Ave. Coach Lines, Inc., 289 F. Supp. 3, 30 (S.D.N.Y. 1968).

8
 See, e.g., United Asset Management Corp., SEC No-Action
Letter (Nov. 2, 1981) (“Based on the facts contained in your letter, however, it appears that [applicant] would not be an investment company as defined in section [3(a)(1)(A)] because its primary business will be owning or holding securities
rather than ‘investing, reinvesting, or trading’ in them compare ‘investing, reinvesting, owning, holding, owning, or trading’ in section [3(a)(1)(C)], and that [applicant] would not be an investment company as defined in
section [3(a)(1)(C)] because ‘investment securities’ is defined to exclude securities issued by majority-owned subsidiaries of the owner which are not themselves investment companies.”); accord Centex Corporation, SEC No-Action Letter (Nov. 20, 1986).

Securities and Exchange Commission

 4

April 25, 2025

 We respectfully disagree with the premise that the Company will be “buying (and selling) securities on
an ongoing basis.” As we have discussed in prior responses, the substantial majority of the Company’s assets will be its interests in its Control JVs and the Company’s interests in those Control JVs are general partner interests, not
securities.9 Moreover, and from a technical standpoint, whether Section 3(a)(1)(A) is tested based on consolidated financials or unconsolidated financials would not change the test’s
application to the Company because the Company expects that its Control JVs will generally not be consolidated with the Company under GAAP.

 The Company
will not be continuously buying and selling securities other than those as needed to manage its Liquidity Portfolio.10 The Company’s Liquidity Portfolio may comprise various types of
securities, and the Company’s activities with respect to the Liquidity Portfolio can be considered “investing, reinvesting, or trading in securities,”11 but “the issue before
us [under Section 3(a)(1)(A)] is not whether applicant engaged in any investment company activities, but rather whether or not it has been primarily engaged in” a securities business.12 It is envisioned and stated clearly in the Registration Statement that the Company’s Liquidity Portfolio securities will, in the ordinary course, be less than 20% of the Company’s total
asset value,13 which is not a “primary” activity.14

Similarly, we disagree with the characterizations that our Control JVs (or Non-Control JVs) themselves will be
“buying (and selling) securities on an ongoing basis.” Under most circumstances, each individual Control JV will buy assets exactly one time, and that is their initial acquisition of the respective portfolio company. While it is possible
that certain transactions could involve follow-on transactions (such as to acquire more control or fund a bolt-on transaction for the portfolio company) or that the
initial transaction will be funded in multiple stages, any additional transactions are expected to be discrete and limited and inextricably related to the initial purchase. At most, any given Control JV would be expected to have a handful of
transactions where it acquires interests in a portfolio company over the span of such Control JV’s entire existence. We do not believe such sporadic activity should be characterized as “ongoing” activity.

9
 See generally our prior response dated November 15, 2024 (our “November 15th Letter”) and our prior response dated December 19, 2024 (our “December 19th Letter”).

10
 As disclosed in the Registration Statement, the Company’s liquidity portfolio may comprise various liquid
securities (including money market fund interests) that would still be considered securities. The Liquidity Portfolio however will be kept to under 20% of the Company’s assets at any given time.

11
 See Section 3(a)(1)(A).

12
 Great American Life Underwriters, Inc., 41 S.E.C. 1, 20 (1960).

13
 See Registration Statement at p. 2 (“We expect that over the long term, Joint Ventures and
portfolio companies will make up approximately 80% of our assets and that the balance of our assets, approximately 20%, will consist of cash and cash equivalents, U.S. Treasury securities, U.S. government agency securities, municipal securities,
other sovereign debt, investment grade credit and other investments including high-yield credit, asset-backed securities, mortgage-backed securities, collateralized loan obligations, leveraged loans and/or debt of companies or assets (collectively,
the ‘Liquidity Portfolio’)”) (internal cross-references omitted).

14
 See Registration Statement at p. 121 (“We plan to generate revenues primarily from our long-term
ownership and control of Joint Ventures and portfolio companies and, to a lesser extent, investments in our Liquidity Portfolio, which may consist of dividend income, interest income, and net realized gains or losses and net change in unrealized
appreciation or depreciation.”).

Securities and Exchange Commission

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April 25, 2025

Once the initial transaction is consummated, the ongoing activity of each Control JV will be with respect to managing its acquired portfolio company, and that activity does not involve
“buying or selling securities on an ongoing basis.”

 Additionally, in our prior response we did not state that the majority of Control JVs would
sell their interests in portfolio companies within three to five years. Our intention was to convey that the Company has a long-term horizon for its investments and expects to hold most of its portfolio companies for at least
three to five years.15 We were intending to provide an estimate for where the Company’s minimum hold period may land, disregarding one-off or
unique circumstances.16 We do not expect that it will be the case that the Company or its Control JVs will routinely sell any portfolio companies in the “ordinary course” within three
years of acquiring said portfolio companies. It also may be the case that the Company’s Control JVs do not sell any assets within five years after initial acquisition. In either scenario, we did not mean to imply that the Company would expect
to have exited the majority of investments within three or five years of first investment. The Company has no estimate to provide with respect to the average length of time a portfolio company will be held, but it almost certainly would be much
longer than three or five years.

 As with respect to acquisition transactions, the extent that any Control JV resolves to exit its underlying portfolio
company, it is the expectation that it will do so in one single transaction. Alternatively, if the Control JV resolves to cause the underlying portfolio company to conduct an IPO, the Control JV may conduct an exit gradually through a staged
sell-down. We also do not believe this pattern would constitute buying and selling on an “ongoing” basis. Given that the Company has not yet begun operations, all that can be said authoritatively is that the Control JVs are expected to
conduct one or a few acquiring transactions. Each Control JV may then, at some indeterminable point in the future, decide to sell or otherwise exit its interests in the portfolio company. The buying and selling transaction (if any) would be spaced
out over the course of a minimum of three to five years, with the distinct likelihood that the average hold time is ma