Correspondence 0001104659-25-041237 from Coatue Innovation Fund (CIK 0002044519)
Coatue Innovation Fund (CIK 0002044519)
Date: April 29, 2025 · CIK: 0002044519 · Accession: 0001104659-25-041237
AI Filing Summary & Sentiment
File numbers found in text: 333-283279, 811-24025
Letter
United States VIA EDGAR United States Securities and Exchange Commission Division of Investment Management Washington, D.C. 20549 Attn: Timothy Worthington Re: Coatue Innovation Fund Registration Statement on Form N-2 (File Nos. 333-283279; 811-24025)
Dear Mr. Worthington:
On behalf of Coatue Innovation Fund (the "Fund"), this letter responds to the comment issued by the staff (the "Staff") of the Securities and Exchange Commission (the "Commission") in a telephone call on April 29, 2025 between Mr. Timothy Worthington of the Staff and Ms. Jessica L. Patrick of Kirkland & Ellis LLP, outside counsel to the Fund, relating to the Fund's amended registration statement on Form N-2/A, filed on April 23, 2025 (File Nos. 333-283279; 811-24025) (the "Registration Statement").
For your convenience, a transcription of the Staff's comment is included in this letter, with the comment followed by the Fund's response. Capitalized terms used but not defined herein have the meanings assigned to them in the Registration Statement.
General
1. Please file correspondence where the Fund includes the undertakings required by Rule 484(b)(3) under the Securities Act of 1933, as amended (the "Securities Act").
Response: As requested, the Fund undertakes as follows:
Insofar as indemnification for liability arising under the Securities Act may be permitted to directors, officers and controlling persons of the Fund pursuant to the provisions described in the Registration Statement, or otherwise, the Fund has been advised that in the opinion of the SEC such indemnification is against public policy as expressed in the Securities Act and is, therefore, unenforceable. In the event that a claim for indemnification against such liabilities (other than the payment by the Fund of expenses incurred or paid by a director, officer or controlling person of the Fund in the successful defense of any action, suit or proceeding) is asserted by such director, officer or controlling person in connection with the securities being registered, the Fund will, unless in the opinion of its counsel the matter has been settled by controlling precedent, submit to a court of appropriate jurisdiction the question whether such indemnification by the Fund is against public policy as expressed in the Securities Act and will be governed by the final adjudication of such issue.
Austin Bay Area Beijing Boston Brussels Chicago Dallas Frankfurt Hong Kong Houston London Los Angeles Miami Munich New York Paris Riyadh Salt Lake City Shanghai
* * * * * *
If you have any questions, please feel free to contact the undersigned by telephone at (202) 389-3475 or by email at jessica.patrick@kirkland.com or Nicole M. Runyan, P.C. by telephone at (212) 446-4774 or by email at nicole.runyan@kirkland.com. Thank you for your cooperation and attention to this matter.
Sincerely,
/s/ Jessica L. Patrick, Esq.
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CORRESP
1
filename1.htm
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
April 29,
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
Registration Statement on Form N-2 (File Nos. 333-283279; 811-24025)
Dear Mr. Worthington:
On
behalf of Coatue Innovation Fund (the "Fund"), this letter responds to the comment issued by the staff (the "Staff")
of the Securities and Exchange Commission (the "Commission") in a telephone call on April 29, 2025 between Mr. Timothy
Worthington of the Staff and Ms. Jessica L. Patrick of Kirkland & Ellis LLP, outside counsel to the Fund, relating to the
Fund's amended registration statement on Form N-2/A, filed on April 23, 2025 (File Nos. 333-283279; 811-24025) (the "Registration
Statement").
For your convenience, a transcription of the Staff's
comment is included in this letter, with the comment followed by the Fund's response. Capitalized terms used but not defined herein have
the meanings assigned to them in the Registration Statement.
General
1. Please file correspondence where the Fund includes the undertakings
required by Rule 484(b)(3) under the Securities Act of 1933, as amended (the "Securities
Act").
Response:
As requested, the Fund undertakes as follows:
Insofar as indemnification for liability
arising under the Securities Act may be permitted to directors, officers and controlling persons of the Fund pursuant to the
provisions described in the Registration Statement, or otherwise, the Fund has been advised that in the opinion of the SEC such
indemnification is against public policy as expressed in the Securities Act and is, therefore, unenforceable. In the event that a
claim for indemnification against such liabilities (other than the payment by the Fund of expenses incurred or paid by a director,
officer or controlling person of the Fund in the successful defense of any action, suit or proceeding) is asserted by such director,
officer or controlling person in connection with the securities being registered, the Fund will, unless in the opinion of its
counsel the matter has been settled by controlling precedent, submit to a court of appropriate jurisdiction the question whether
such indemnification by the Fund is against public policy as expressed in the Securities Act and will be governed by the final
adjudication of such issue.
Austin
Bay Area Beijing Boston Brussels Chicago Dallas Frankfurt Hong Kong Houston London Los Angeles  Miami Munich New York
Paris Riyadh Salt Lake City Shanghai
* * * * * *
If
you have any questions, please feel free to contact the undersigned by telephone at (202) 389-3475 or by email at jessica.patrick@kirkland.com
or Nicole M. Runyan, P.C. by telephone at (212) 446-4774 or by email at nicole.runyan@kirkland.com. Thank you for your cooperation and
attention to this matter.
Sincerely,
/s/ Jessica L. Patrick, Esq.
Jessica L. Patrick
cc: Claire Jen, Esq., Coatue
Management, L.L.C.
Nicole M. Runyan, P.C., Kirkland & Ellis
LLP