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    Jessica Patrick

    To Call Writer Directly:

    +1 202 389 3475

    jessica.patrick@kirkland.com

    1301 Pennsylvania Avenue, N.W.

    Washington, D.C. 20004

    United States

    +1 202 389 5000

    www.kirkland.com

    Facsimile:

    +1 202 389 5200

February 7, 2025

VIA EDGAR

United States Securities and Exchange Commission

Division of Investment Management

100 F Street, N.E.

Washington, D.C. 20549

Attn: Timothy Worthington

 Re: Coatue Innovation Fund
                                            (formerly, Coatue CTEK Fund)

                                            Registration Statement on Form N-2 (File Nos. 333-283279; 811-24025)

Dear Ladies and Gentlemen:

On behalf of Coatue Innovation Fund (formerly,
Coatue CTEK Fund) (the "Fund"), we hereby respond to the comments raised by the staff (the "Staff")
of the Securities and Exchange Commission (the "Commission") regarding the Fund's amended Registration Statement on
Form N-2/A, filed on November 19, 2024 (File Nos. 333-283279; 811-24025) (the "Registration Statement"), in
written correspondence, dated December 19, 2024 from Timothy Worthington of the Staff to Jessica L. Patrick of Kirkland &
Ellis LLP, outside counsel to the Fund. The Fund is filing Pre-Effective Amendment No. 2 (the "Amendment") to the
Registration Statement concurrently hereto to respond to the Staff's comments and make certain other changes.

For your convenience, a transcription of the
Staff's comments is included in this letter, with each comment followed by the Fund's response. Please note that we have not independently
verified information provided by the Fund. References in the responses to the Fund's Prospectus or Statement of Additional Information
("SAI") are to those filed as part of the Amendment. Capitalized terms used but not defined herein have the meanings
assigned to them in the Amendment.

General

 1. We note that portions of the Registration
                                            Statement are incomplete. Please ensure all information is included in a pre-effective amendment,
                                            including the fee table, hypothetical expense examples, references to the auditor, auditor's
                                            consent, and seed financial statements. A full financial review must be performed prior to
                                            declaring the Registration Statement effective. We may have additional comments on such portions
                                            when the Fund completes them in a pre-effective amendment, on disclosures made in response
                                            to this letter, on information supplied supplementally, or on exhibits added in any amendment.

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Response:

The Fund confirms that it will provide the requested
information in a pre-effective amendment.

 2. Please advise the Staff of the status of
                                            any exemptive application(s) or no-action request(s) that the Fund or the Adviser,
                                            has submitted or intends to submit in connection with your Registration Statement, including
                                            with respect to co-investments and multi-class relief.

Response:

The Fund submitted an application for an exemptive
order from the Commission to be able to issue multiple class of its common equity (the "Multi-Class Application"). The
Multi-Class Application was filed on the EDGAR system on December 5, 2024 (File No. 812-15666) and was noticed by the
Commission on December 13, 2024 and granted on January 8, 2025. Additionally, the Fund submitted an application (the "Co-Investment
Application") for an exemptive order to participate in a proposed co-investment program. The Co-Investment Application was filed
on the EDGAR system on November 15, 2024 (File No. 812-15659). The Fund does not intend to seek any other exemptive or no-action
relief from the Commission or its Staff.

 3. Please supplementally explain if the Fund
                                            has presented or will present any "test the waters" materials to potential investors
                                            in connection with this offering. If so, please provide the Staff with copies of such materials.

Response:

The Fund supplementally confirms that no test-the-waters
materials have been presented to potential investors in connection with this offering.

 4. Please confirm that any credit agreements
                                            the Fund has entered into or will enter into prior to effectiveness will be filed as exhibits
                                            to the Registration Statement.

Response:

The Fund has not entered into, and prior to the
effectiveness of the Registration Statement, does not expect to enter into any credit agreements.

 5. Please supplementally explain whether the
                                            Fund intends to issue preferred or debt securities within a year from the effective date
                                            of the Registration Statement.

Response:

The Fund supplementally confirms that it has
no current intention of issuing preferred or debt securities within a year from the effective date of the Registration Statement.

 6. Please confirm that FINRA will review the
                                            underwriting terms and arrangements of the offering.

Response:

The Fund respectfully notes that the offering
of its Shares to the public is not subject to a FINRA review because it is an exempt offering pursuant to FINRA Rule 5110(h)(2)(L).

 7. Please supplementally explain whether the
                                            entity will be seeded in a formation transaction. If so, please provide an analysis addressing
                                            the applicability of S-X 6-11.

Response:

The Fund does not currently anticipate receiving
any seed capital in a formation transaction that would trigger the application of Rule 6-11 under Regulation S-X.

 8. Certain disclosures in the Registration
                                            Statement indicate that the Fund may invest in spot crypto assets, including the native crypto
                                            assets of public, permissionless blockchains and/or applications running on such blockchains
                                            (see page 8). Please supplementally explain how the Fund would comply with the custody
                                            requirements of the Investment Company Act of 1940 (the "Act") with respect to
                                            these investments. See Section 17(f) of the Act. The Staff may have additional
                                            comments.

Response:

The Fund intends to comply with the custody requirements
of Section 17(f) of the Investment Company Act of 1940 (the "1940 Act") with respect to any investments in spot crypto
assets. Specifically, the Fund will hold spot crypto assets with a qualified custodian that meets the requirements under Rule 17f-1,
Rule 17f-2, or Rule 17f-4, as applicable. The qualified custodian will provide the necessary safeguards to ensure compliance
with the 1940 Act's requirements, including maintaining custody of the assets in a manner designed to prevent loss, theft, or unauthorized
use. For crypto assets held through third-party custodians, the Fund will ensure that the custodian meets industry standards for safeguarding
digital assets, including robust security measures such as multi-signature wallets, cold storage, and regular third-party audits. In
addition, the Fund's Board of Trustees will oversee the custody arrangements to ensure compliance with the 1940 Act and to address any
unique risks associated with spot crypto assets. The Board will periodically review the Fund's custody practices and the qualified custodian's
policies to ensure ongoing compliance.

 9. The Staff notes that the Registration Statement
                                            contains both an "Executive Summary" section and a "Summary of Offering Terms"
                                            section. The "Executive Summary" in large part relates to the Adviser and not specifically
                                            to the Fund. Additionally, parts of the "Executive Summary" cover similar concepts
                                            and issues as the "Summary of Offering Terms." Please combine the disclosures into
                                            a single synopsis that focuses on the Fund. The synopsis should be a clear and concise description
                                            of the key features of the offering and the Registrant and should not impede understanding
                                            of the information required to be presented in the prospectus. See Item 3.2 in Form N-2;
                                            see also Guide 7 to Form N-2. In this regard, we note the following:

 a. The Executive Summary section and the
                                            Summary of Offering Terms include broad statements regarding the Fund's proposed investment
                                            strategy. Please review and revise to make the disclosures discussing the Fund's principal
                                            investment strategy more precise or consider moving such disclosures out of the synopsis.
                                            When revising the synopsis, please make sure it briefly summarizes the key features of the
                                            offering and that the disclosure is otherwise consistent with the more detailed discussion
                                            about the Fund's strategy in latter sections of the prospectus.

 b. Similarly, the Executive Summary includes
                                            lengthy disclosures about the background and history of the Adviser which would be more appropriately
                                            included elsewhere in the Registration Statement without impeding understanding of other
                                            information regarding key features of the Fund and the offering.

Please make sure to provide cross-references
to relevant disclosures elsewhere in the prospectus and SAI that provide additional details about key features of the offering and Fund.

Response:

The Fund has revised the disclosure in the Prospectus
in response to this request.

 10. The Staff notes that throughout the Registration
                                            Statement, the disclosure (a) describes the Fund's principal investment strategy using
                                            broad references to various types of investments that the Fund may make; and (b) uses
                                            hedging language, such as "not limited to", "certain", "including",
                                            "other factors" to describe the Adviser's investment selection process. Please
                                            revise the disclosure to clarify, with specificity, the nature of, and types of investments
                                            the Fund will make as part of its principal investment strategy, as well as how those
                                            investments are selected. Please also move any discussion of non-principal strategies and
                                            investments to later sections of the Registration Statement, as appropriate. See for example,
                                            disclosure on the Cover Page that discloses "the Fund may [emphasis added]
                                            allocate capital to private investments in public equity ('PIPEs')";
                                            see also, disclosure in the "Proprietary Data Science Capabilities" sub-section
                                            on page 2, stating that "while AI may [emphasis added] be utilized
                                            by Coatue's investment team in connection with the research
                                            process, investment decisions will continue to be made by Coatue's investment personnel."

Response:

The Fund acknowledges the Staff's comment and
has made revisions throughout the Registration Statement to clarify the Fund's principal investment strategy and the types of investments
the Fund will make as part of that strategy. Specifically, the revised disclosure provides additional detail about the nature of these
investments and how the Adviser intends to select them, while moving discussions of non-principal strategies and investments to later
sections, as appropriate.

With respect to the use of the term "may,"
the Fund respectfully submits that in certain instances this term is used intentionally and accurately to describe investment activities
that are not definitive but remain potential components of the Fund's strategy. For example, the Fund may allocate capital to investments
such as private investments in public equity (PIPEs) or utilize artificial intelligence (AI) tools in the research process. In these
contexts, using "may" appropriately reflects the Fund's flexibility to pursue or forego these activities depending on market
conditions, investment opportunities, or other relevant factors. To state definitively that the Fund "will" engage in such
activities when they are not guaranteed could mislead investors and imply commitments that do not align with the Fund's intended operations.

Cover Page i-iii

 11. The first sentence of the first paragraph
                                            discloses that, "the Fund seeks to achieve its investment objective by investing, under
                                            normal circumstances, at least 80% of its net assets (plus the amount of any borrowings for
                                            investment purposes) in private and public 'Tech and Innovation Companies.'" The Staff
                                            notes that the Fund's name includes the term "TEK" which suggests that the Fund's
                                            investment focus will be in the technology sector. Please supplementally explain how it is
                                            consistent with rule 35d-1 of the Act to include "Innovation Companies" in
                                            the Fund's 80% test. We note "Tech and Innovation Companies" are defined broadly
                                            to include non-tech companies and companies that "operate in adjacent industries"
                                            to "Tech and Innovation Companies." The Staff may have additional comments.

Response:

The Fund has changed its name to "Coatue
Innovation Fund." The Fund confirms that it will comply with Rule 35d-1 under the 1940 Act by investing, under normal circumstances,
at least 80% of its net assets (plus the amount of any borrowings for investment purposes) in "Innovation Companies" as defined
in the Registration Statement.

The Fund’s name reflects its broad focus
on innovation, encompassing both primary and secondary innovation. The Fund views innovation as extending beyond traditional technology
companies to include sectors disrupted by or driving innovation. To that extent, the Fund’s 80% policy has been updated to clarify
that “Innovation Companies” includes companies innovating directly within their sectors, as well as those facilitating