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  Eversheds Sutherland (US) LLP

700 Sixth Street, NW, Suite 700

Washington, DC 20001-3980

D: +1 202.383.0176

F: +1 202.637.3593

stephanihildebrandt@eversheds-
sutherland.com

                        April 17, 2025

Via EDGAR

Timothy Worthington, Senior Counsel

U.S. Securities and Exchange Commission

Division of Investment Management

100 F Street NE

Washington, DC 20549

 Re: LAGO Evergreen Credit, Registration Statement on Form 10

    File No. 000-56728

Dear Mr. Worthington:

On behalf of LAGO Evergreen Credit (the “Company”),
set forth below is the Company’s response to legal comments provided by the staff of the Division of Investment Management (the
“Staff”) of the U.S. Securities and Exchange Commission (the “SEC”) on April 2, 2025 regarding the Company’s
registration statement on Form 10 (File No. 000-56728) (the “Registration Statement”) as filed with the SEC on March 3, 2025.
The Staff’s legal comments from April 2, 2025 are set forth below and are followed by the Company’s responses. Where applicable,
revisions to the Registration Statement referenced in the below responses are set forth in an amended Registration Statement on Form 10
(File No. 000-56728) (the “Amended Registration Statement”), concurrently filed herewith.

General

 1. Comment: Portions of the registration statement are incomplete. We may have additional comments
on such portions when you complete them.

    Response: The Company
acknowledges the Staff’s comment.

 2. Comment: Please advise the Staff of the status of any exemptive application(s) or no-action
request(s) that the Company or the Investment Adviser, submitted or intends to submit in connection with your Registration Statement,
including with respect to co-investments.

    Response: On November 20,
2024, as amended on March 12, 2025, the Company, LAGO Asset Management, LLC (the “Investment Adviser”) and certain of its
affiliates filed an application (the “Application”) for an order (the “Order”) under Sections 17(d) and 57(i)
of the Investment Company Act of 1940, as amended, and Rule 17d-1 thereunder, to permit co-investments, which might otherwise be prohibited
by Sections 17(d) and 57(a)(4). On March 26, 2025, the Staff issued a notice of its intention to grant the Order (SEC Release IC-35512).
In addition, the Company, the Investment Adviser and certain of its affiliates intend to file a new application (the “New Application”)
for an order under Sections 17(d) and 57(i) of the Investment Company Act of 1940, as amended, and Rule 17d-1 thereunder, to permit co-investments,
which might otherwise be prohibited by Sections 17(d) and 57(a)(4)

Via EDGAR

Timothy Worthington, Senior Counsel

April 17, 2025

Page 2

    consistent with the new form of co-investment
exemptive relief order recently approved by the SEC.

 3. Comment: Please consider including a fee table and an expense example that conforms to the
requirements of Item 3.1 of Form N-2.

Response: The Company acknowledges
the Staff’s comment and respectfully declines to add the requested disclosure. The Company notes that Form 10 does not require such
disclosure and such disclosure has not been included in the Form 10 registration statements of many other private business development
companies.

 4. Comment: Please state in your response when the Company intends to file an election
to be regulated as a BDC.

    Response: The Company filed
an election on Form N-54A to be regulated as a BDC on March 3, shortly after filing the Registration Statement.

 5. Comment: Please confirm whether the Company does not intend to issue debt securities or
preferred stock within a year from the effective date of the Registration Statement.

    Response: The Company confirms
that it does not intend to issue debt securities or preferred shares within one year of the effectiveness of the Amended Registration
Statement.

 6. Comment: Please attach as exhibits to the filing all material credit agreements that are
in place or will be in place prior to the Company’s launch.

    Response:
The Company confirms that, prior to effectiveness of the Registration Statement, it will attach as exhibits to the filing all material
credit agreements to which the Company is a party.

 7. Comment: Please file an amended Form 10 filing with complete financial statements at least
15 days prior to the Form 10’s effectiveness.

    Response: The Company confirms
that complete financial statements have been included in the Amended Registration Statement.

 8. Comment: The Staff notes the Company’s name includes the word “Credit.”
Please adopt an 80% policy to invest in credit investments. See Section 59 and Rule 35d-1 under the Investment Company Act of 1940 (“1940
Act”).

    Response: The Company has
adopted a policy to invest at least 80% of its assets in “credit,” which the Company defines as debt investments made in exchange
for regular interest payments. The Company has also modified the disclosure on pages 1 and 54 of the Amended Registration Statement in
response to the Staff’s comment.

Explanatory Note

 9. Comment: On the Cover Page, please prominently disclose, as applicable that:

 a. The Company’s common stock is not currently listed on an exchange, and it is uncertain whether a
secondary market will develop.

Via EDGAR

Timothy Worthington, Senior Counsel

April 17, 2025

Page 3

 b. Repurchases of common stock by the Company, if any, are expected to be very limited.

 c. An investment in the Company may not be suitable for investors who may need the money they invest in a
specified time frame.

 d. Investment in the Company is suitable only for sophisticated investors and requires the financial ability
and willingness to accept the high risks and lack of liquidity inherent in an investment in the Company.

 e. The Company intends to invest primarily in privately-held companies for which very little public information
exists. Such companies are also generally more vulnerable to economic downturns and may experience substantial variations in operating
results.

 f. The privately held companies and below-investment-grade securities in which the Company will invest will
be difficult to value and are illiquid.

  Response: The Company
respectfully advises the Staff that its Registration Statement is a voluntary registration statement under the Exchange Act, and that
such Registration Statement is not an offering document and does not include a prospectus that will be used to offer securities registered
under the Securities Act. Instead of a prospectus, the Company will offer its securities via private placement memoranda or other offering
materials pursuant to one or more exemptions from registration under the Securities Act, including under Regulation D. The Company’s
offering material may contain information that is more detailed than, or in addition to, the information included in its Registration
Statement, and no portion of the Registration Statement is required to be included in the Company’s private placement memoranda.
As such, the Company’s Registration Statement generally omits extensive disclosure relating to the offering of its securities, including
the risks and expenses associated with ownership, the markets for such securities, and similar offering-related information as it is not
required to be included in a registration statement on Form 10 filed under the Exchange Act. As a result, the Company respectfully declines
to include the requested additional disclosure in the Registration Statement.

Item 1. The Company, Page 1

 10. Comment: The first sentence of the second paragraph discloses that “The Company was
formed to serve as a direct lender to primarily U.S.-based [emphasis added] lower middle market companies . . .” Please similarly
clarify how the Company determines a company is U.S.-based.

    Response: The Company
has revised the disclosure as requested.

 11. Comment: Please disclose if the Company has any maturity, duration, and quality requirements
with respect to its investments. To the extent the Company has no such requirements, please disclose as much.

    Response: The Company
advises the Staff that it does not have specific maturity, duration and quality requirements with respect to its investments and has added
disclosure on page 5 to this effect.

Via EDGAR

Timothy Worthington, Senior Counsel

April 17, 2025

Page 4

 12. Comment: The last sentence of the paragraph discloses that, “The Company’s aim
is to invest primarily in floating rate senior secured term loans used to finance the continued growth and expansion of predominantly
U.S.-based companies that are likely to be sponsored by venture capital, growth equity [emphasis added], private equity or family
office firms. Please clarify how “growth equity” differs from “venture capital” or “private equity.”

    Response: The Company
has revised the disclosure to remove the term “growth equity”.

 13. Comment: The first sentence of the third paragraph discloses that the Company will invest
in “equity-linked investments, such as warrants,” while the second sentence of the same paragraph discloses that the Company
will investment in “equity-related securities, such as convertible notes, warrants, and preferred or common stock. Please clarify
if there is a difference between “equity-linked investments” and “equity-related securities” and consider using
the same term to describe the Company’s principal investments. Furthermore, please consistently disclose the types of principal
investments contemplated by these categories, and as necessary, include corresponding risk disclosure.

    Response: The Company
has revised the disclosure to remove references to equity-linked investments.

 14. Comment: Please disclose whether the Company will invest in “covenant lite”
loans, and to the extent applicable, include corresponding risk disclosure.

    Response: The Company
made the requested disclosures on page 47 of the Amended Registration Statement in response to the Staff’s comment.

Item 1. The Investment Adviser, Page
2

 15. Comment: Disclosure in the first paragraph states that, “As a result of the collective
longevity investing capital among its investment team, the Investment Adviser has developed an expansive network of venture capital, growth
equity, private equity, and other private credit funds and relevant service . . .” Please clarify that this disclosure is the belief
of the Adviser.

    Response: The Company
has clarified that the statement is a belief of the Investment Adviser.

Item 1. Formation Transaction, Page 3

 16. Comment: The section discloses investments from a “legacy portfolio.” Please
disclose in correspondence if the Company would be responsible for any capital commitments made by the Legacy Portfolio.

    Response: The Company
acquired the Legacy Portfolio in connection with the merger of the Legacy Fund with and into the Company with the Company as the surviving
entity. As a result of the merger, the Company became the party in interest to the legacy portfolio and, as such, the Company will be
responsible for any capital commitments made by the Legacy Fund to portfolio companies that are part of the Legacy Portfolio.

Via EDGAR

Timothy Worthington, Senior Counsel

April 17, 2025

Page 5

Item 1. Company Strategy, Pages 4-5

 17. Comment: Within the last sentence of the first paragraph, the disclosure states that “The
Company will seek to generate a gross unlevered yield of between 8% - 15% on floating rate senior secured credit positions, which it expects
to be enhanced by appreciation from warrants in growing companies.” Please clarify that there is no guarantee that the Company will
generate such yield and that the amount of distributions that the Company may pay, if any, is uncertain.

    Response: The Company
has revised the disclosure as requested.

 18. Comment: The second paragraph discloses that “The Company will seek to offer loans
in amounts that represent a more conservative loan-to-value [emphasis added] (“LTV”) (typically less than 50%), based
on market value, relative to levels seen in larger market transactions . . . Please clarify that the characterization of loans offered
by the Company is the belief of the Adviser.

    Response: The Company
has revised the disclosure to clarify that this statement is the belief of the Investment Adviser.

 19. Comment: The second paragraph discloses that “Relative to other credit investment
opportunities, lower middle market lending has demonstrated lower default rates and higher recovery rates compared to the larger corporate
lending markets in the recent past.” Please substantiate the statement, or delete.”

    Response: The Company
has revised the disclosure as requested.

 20. Comment: The last paragraph discloses, in pertinent part, that “The Company may make
these equity investments, on an opportunistic basis, based on what the Company believes to be in the best interests of the Shareholders.
To the extent the Company determines not to invest, in whole or in part, in any such opportunity, certain of the Company’s affiliated
investment funds may use these rights-to-invest foregone by the Company to fulfill the equity investment opportunity.” Please explain
in correspondence how an affiliated fund’s investment in the Company’s forgone contractual opportunities will be structured
to comply with Section 17.

    Response: The Company
respectfully advises the Staff that the Company has and may have affiliated entities that are neither registered investment companies
nor regulated under the 1940 Act. Those affiliated entities would not be required to comply with the requirements of the 1940 Act
applicable to registered investment companies, including Section 17.

 21. Comment: The last sentence of the last paragraph discloses that “the Company expects
that no more than 5 to 10% of its invested capital, on a cost basis, will be invested in non-income generating equity investments.”
Please consider more prominently disclosing the statement within the section entitled “The Company” on page 1.

    Response: The Company has added disclosure
under section entitled “The Company” on page 1 of the Amended Registration Statement.

Item 1. Competitive Strengths, Page 6

Via EDGAR

Timothy Worthington, Senior Counsel

April 17, 2025

Page 6

 22. Comment: The subsection, “Well-developed Direct Originations Capabilities Based on
Thematic Investing” discloses that the Investment Adviser pursues an investment strategy based around certain macrotrends, including
those “where significant innovation will occur over the long term.” Please revise to clarify that such statement is the opinion
of the Investment Adviser. Additionally, the disclosure states that “[s]uch themes include tech and tech-enabled services focused
on sectors including, but not limited to, Artificial Intelligence, Enterprise SaaS, Mobility . . . Please clarify what is meant by Enterprise
SaaS and Mobility.

    Response: The Company
has revised the disclosure to clarify that this statement is a belief of the Investment Adviser. The Company also modified the disclosure
to further describe Enterprise SaaS on page 6 of the Amended Registration Statement.

 23. Comment: The subsections “Disciplined Investment and Underwriting Process,”
“Cycle-tested Investment Team,” and “Opportunistic Growth Investing” include broad statements regarding the Investment
Adviser’s background and track record, including as compared to other investment firms. Please review and revise the disclosures
to clarify that such statements are the opinion of the Investment Adviser.

    Response: The Company
has revised the disclosures to clarify that these are opinions or beliefs of the Investment Adviser.

Item 1. Investment Process Overview, Page 7

 24. Comment: The first sentence of the first paragraph discloses that, “The Company expects
that for a majority of its investment positions, it will se