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CORRESP
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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
 August 8, 2025

 Re:
 EQT Infrastructure Company LLC
 Post-Effective Amendment No. 2 to Registration Statement on Form 10-12G
 Filed April 25, 2025 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 hereby file this letter with the Securities and Exchange Commission
(the “Commission”) in response to comments received from the staff of the Commission (the “Staff”) by the Company on June 6, 2025, with respect to the above-referenced registration statement on Form 10 (the
“Registration Statement”). 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 the Registration Statement. Unless otherwise defined below, terms defined in the Registration Statement and used below shall have the meanings given to them in the Registration
Statement. The responses and information described below are based upon information provided to us by the Company. General

 1.
 Comment : We note in your response to prior comment 2 that you “respectfully disagree[s] with the
premise that the Company will be ‘buying (and selling) securities on an ongoing basis…” while also stating as follows: (i) “the Company intends to be a diversified holding company”; (ii) “the Company is in the business
of acquiring high quality portfolio companies with the potential to continue to thrive over time”; and (iii) “the Company will exercise control over its portfolio companies”. Your Investment Company Act status analysis appears to
disregard some of the Control JVs’ activities (because you do not plan to consolidate the Control JVs under GAAP), despite the fact that you represent yourself publicly and in your Investment Company Act status analysis as a diversified holding
company operating portfolio companies (which implies consideration of the operation of portfolio companies undertaken by the Control JVs). See generally Certain Prima Facie Investment Companies, Release No.
 IC-10937 (Nov. 13, 1979) (a “holding company generally secures control of other companies primarily for the purpose of engaging in the other companies’ line of business”). We have the following
related comments: Please explain or resolve this apparent inconsistency.

 Securities and Exchange Commission

 2

 August 8, 2025
 Response : The Staff’s comment suggests the apparent inconsistency you perceive is between
(x) our analysis stating that “the Company,” meaning the Company and its subsidiaries consolidated under U.S. generally accepted accounting principles (“GAAP”), will not be engaged in buying and selling securities on an
ongoing basis, which goes towards the application of the assets and/or income factors under Tonopah , 1 and (y) the Company’s narrative disclosures, which you suggest collapse some
actions of the Company’s Control JVs with the Company and therefore “implies consideration” of the Control JVs as part of the Company’s analysis, which may implicate the Tonopah factor that considers the Company’s
public representations of policy. We respectfully disagree with the suggestion that the Company’s Investment Company Act analysis is inconsistent or incomplete.
 Section 3(a)(1)(A) interrogates whether an issuer is, or holds itself out as being, primarily engaged in the business activities of investing,
reinvesting, or trading in securities. 2 To determine what business activity an issuer is primarily engaged in, the Commission has held that an issuer must apply the five-factor test outlined in
 Tonopah . Those five factors are: (1) an issuer’s historical development, (2) its public representations of policy, (3) the activities of its officers and directors, (4) the nature of its present assets, and
(5) the sources of its present income (collectively, the “ Tonopah Factors”). 3 As we set out in our prior comment response letters (the “Prior Letters”), we do not
believe that the Company is primarily engaged in the business of investing, reinvesting or trading in securities after an application of the Tonopah Factors. 4
 In response to your comment, we first explain our view that our application of Tonopah ’s assets and income tests by reference to GAAP consolidated
financials is logical and correct, and consistent with our understanding of the historical views of the Commission and its Staff. Second, we explain why the Company’s narrative disclosures do not inform how the Company analyzes its assets and
income for purposes of the Tonopah test, as applied by the Commission, its Staff and market participants over time. Third, we explain why we do not believe that the Staff has correctly characterized the Company’s disclosures.

 1
 In re Tonopah Mining Co. of Nevada, 26 S.E.C. 426 (1947) (“ Tonopah ”).

 2
 See Section 3(a)(1)(A) of the Investment Company Act. Unless otherwise specified, all references
herein to sections and rules are references to sections and rules promulgated under the Investment Company Act.

 3
 See Tonopah at 427.

 4
 See generally our prior letters dated November 15, 2024 (our “November Letter”),
December 19, 2024 (our “December Letter”), and April 25, 2025 (our “April Letter”) (collectively, our “Prior Letters”).

 Securities and Exchange Commission

 3

 August 8, 2025
 The Application of Tonopah and Our Use of GAAP Consolidation
 The Staff’s comment suggests that our “Investment Company Act status analysis appears to disregard some of the Control JVs’ activities.” We
disagree with this suggestion. Our analysis does not consolidate the activities ( i.e. , the assets and income) of the Control JVs, but that does not mean that our analysis does not consider the assets and income of the Control
JVs. Our analysis considers the assets and income of the Control JVs in the Company’s analysis in the same way it considers the assets and income of any other unconsolidated subsidiary when applying Investment Company Act status tests, as
entries on the balance sheet reflecting the value of the Company’s interest in that subsidiary. This approach is consistent with our understanding
of how Investment Company Act status testing is conducted across the board. For example, under Rule 3a-1 and Rule 3a-8 (which incorporates, to a degree, the
 Tonopah factors), it is explicitly stated that an issuer must test its assets and income on an unconsolidated basis except that the issuer’s wholly owned subsidiaries must be consolidated with the issuer. That does not mean that the
issuer’s non-wholly owned subsidiaries are “disregarded” under the Rule 3a-1 or Rule 3a-8 analysis. It means that
those unconsolidated majority-owned or primarily controlled subsidiaries are considered on a standalone, disaggregated basis, and then the result of that separate analysis is used to inform elements of the parent’s analysis. 5 The same is true for the Company’s analysis under Section 3(a)(1)(A). As we indicated in our
Prior Letters, the Company will examine its unconsolidated subsidiaries on a standalone basis to determine whether they should be treated as securities-related or non-securities related for purposes of the
Company’s analysis. We have determined that the Company’s Control JVs are appropriately considered non-securities-related investments while the Company’s
 Non-Control JVs should be considered securities-related investments. The Company does not intend to allocate its
assets such that securities-related assets such as the Non-Control JVs will comprise the majority of its assets. Rather, as the Company has explained, the Company’s intention is that the Company’s
interests in its Control JVs—which will not be deemed investment companies under either Section 3(a)(1)(A) or 3(a)(1)(C) when analyzed on a standalone basis—will comprise the large majority of the Company’s assets by value.
 The Company does not consolidate each JV’s assets or income with those of the Company for purposes of the assets and income factors under the
 Tonopah test because the expectation is that the Company’s JVs will not be consolidated with the Company under GAAP. Accordingly, the underlying assets held by the Company’s JVs ( e.g. , interests in portfolio companies) and
any income related to those interests would not be attributed directly to the Company through consolidation. Those assets and sources of income will instead appear on the Company’s consolidated financial statements as unconsolidated entries,
and those line items will be considered as part of the analysis. 6

 5
 For example, an issuer would evaluate each subsidiary to determine whether it would qualify as a majority-owned
subsidiary or a primarily controlled subsidiary and then also analyze whether each subsidiary would be deemed an investment company but for the exemptions in Section 3(c)(1) and 3(c)(7). The parent’s interest in a majority-owned or
primarily controlled subsidiary that is not an investment company or relying on 3(c)(1) or 3(c)(7) would be considered non-securities-related and therefore a “good” asset under the parent’s Rule
 3a-1 or 3a-8 test.

 6
 We note, regardless, that the Company’s JVs themselves are not in the business of buying and selling
securities on an ongoing basis, but rather in the business of owning and holding interests in portfolio companies.

 Securities and Exchange Commission

 4

 August 8, 2025
 In Tonopah, the Commission stated:
 “More important [than narrative representations in the issuer’s disclosure], however . . . the nature of the assets and income of the company,
disclosed in the annual reports filed with the Commission and in reports sent to stockholders, was such as to lead investors to believe that the principal activity of the company was trading and investing in securities.” 7 The Company’s financial statements will be prepared and presented to investors and the public in
accordance with GAAP. In that regard, the investor-facing presentation of financial statements is what appears most directly relevant to questions presented under Tonopah ’s assets and income factors ( i.e. , what would a reasonable
investor conclude based on what they are presented about the Company’s assets and income). The Company’s decision to analyze its prospective assets and income based on the expected GAAP presentation is consistent with how we understand
most industry participants apply the Tonopah test under Section 3(a)(1)(A). 8
 As discussed in a prior response, 9 Section 3(a)(1)(A) is silent on whether its tests should be run
on a fully unconsolidated basis (as is required by Section 3(a)(1)(C)), on a consolidated basis with only the Company’s wholly owned subsidiaries (as is required by Rule 3a-1 and Rule 3a-8), or on a GAAP consolidated basis (as is required for Exchange Act reports). While we are aware of instances in which the Commission or Staff have considered the assets or income of issuers using each of the
methodologies described above while applying Tonopah , we are aware of no precedent in which the Commission has stated or accepted an analysis under Tonopah conducted on a consolidation basis that included more subsidiaries than
would be consolidated under GAAP. As outlined in our Prior Letters, we believe the Company’s methodology for applying the Tonopah test under
Section 3(a)(1)(A) is not only consistent with applicable precedent and accounting guidance, 10 it is the most appropriate approach under the legal and analytical framework underlying
 Tonopah . Importantly, the Company’s approach is also consistent with how the Staff previously directed the Company to evaluate investment
company status under Tonopah . In the Staff’s first comment letter, to which we replied in our November Letter, the Staff asked that we:
 “Please provide a comprehensive legal analysis regarding whether (i) you (together with your consolidated subsidiaries) and (ii) any
unconsolidated subsidiaries, including any unconsolidated joint ventures formed between you and ‘other sources of capital’ (each, a ‘JV’), meet the definition of an ‘investment company’ under Section 3(a)(1)(A) of
the Investment Company Act of 1940.” 11

 7
 See Tonopah at 430 (emphasis added).

 8
 See, e.g. , Investment Company Act Determination Under the 1940 Act – Vol. 3 – Robert Rosenblum
2025 §3.4.2 Consolidation with an Issuer’s Subsidiaries.

 9
 See April Letter at 3.

 10
 As discussed further, it is our understanding that in undertaking the Tonopah analysis, industry
participants and, notably, the Staff itself, routinely analyze an issuer’s assets and income under generally accepted accounting principles and, in fact, the Commission and the Staff require as much. See Certain Research and Development
Companies, Release No. IC-25835 (Nov. 26, 2002) (Commission statement suggesting that U.S. GAAP is to be utilized to measure an issuer’s compliance with Section 3(a)(1)(C) under the Investment
Company Act). See also Rule 2a-5 Adopting Release, Good Faith Determination of Fair Value, 86 FR 748, 772 (Jan. 6, 2021) (stating that a valuation method not determined in accordance with U.S. GAAP is
misleading and/or inaccurate and therefore an inappropriate methodology under Rule 2a-5).

 11
 See November Letter at 23.

 Securities and Exchange Commission

 5

 August 8, 2025
 In accordance with the Staff’s comment, we evaluated the Company and its consolidated subsidiaries and
then separately, we analyzed the Company’s unconsolidated subsidiaries, with a particular focus on its JVs. Our analysis was then, and remains, consistent with both Tonopah and the Staff’s instructions.
 The Interplay Between the Company’s Narrative Disclosure and the Attribution of Assets and Income Under Tonopah
 The Staff’s comments suggest that the Staff believes that our Investment Company Act status analysis should attempt to “consistently exclude all of
the activities that [the Company] cause[s] Control JVs to undertake (including the Control JVs’ operation of portfolio companies)” if it is to be consistent with our conclusion that the Company’s primary business activity is owning,
managing and controlling its interests in Control JVs. We do not agree with this suggestion. We think it is important to note that the consideration of
an issuer’s activities is not one of the Tonopah Factors. Rather than being an input to the Tonopah test, the issuer’s primary business activities is the output of Tonopah analysis. For example, one of
the factors is the activities of the issuer’s officers and directors , precisely because how an issuer’s officers and directors spend their time is indicative of an issuer’s primary business activities – the test does not
start with the activities of the issuer as a premise. Similarly, the Tonopah test looks to the nature of an issuer’s assets and the source of its income as separate factors, because how an issuer’s assets are deployed and how it
earns income inform what business activities are attributable to the issuer and in what proportions. An issuer’s public representations of policy, which would incorporate consideration of narrative disclosures about how the issuer intends to
operate, is another of the five factors. Importantly, however, the public representations factor is just one of the five Tonopah Factors. What an issuer says in its public representations does not dictate or change how the issuer’s
assets and income should be analyzed, nor do narrative disclosures necessarily outweigh the assets and income factors. An issuer’s narrative
disclosure around how it intends to operate its business does not mean that the fundamental parameters for applying Tonopah change for that issuer. For example, if applying Rule 3a-8 to two issuers with
the exact same assets an