SecProbe.io

CORRESP
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EGAN NELSON LLP

VIA EDGAR

May 9, 2025

Ms. Stacie Gorman

Division of Corporation Finance

Office of Real Estate and Commodities

Securities and Exchange Commission

100 F. Street, N.E.

Washington D.C. 20549

 Re: Connect Invest III LLC

Offering Statement on Form 1-A

File No. 024-12602

Dear Ms. Gorman:

This letter is submitted on behalf
of Connect Invest III LLC (the “Company”) in response to the comments of the staff (the “Staff”) of the Division
of Corporation Finance (the “Division”) of the U.S. Securities and Exchange Commission (the “Commission “) with
respect to the Company’s Offering Statement on Form 1-A filed on April 16, 2025 (“Offering Statement”), as set forth
in your letter dated May 2, 2025 addressed to Mr. Todd B. Parriott, Chief Executive Officer of the Company (the “Comment Letter”).
The Company is concurrently filing an amendment (the “Amendment”) to the Offering Statement, which includes changes made to
the Offering Statement to reflect responses to the Staff’s comments.

For reference purposes, the text
of the Comment Letter has been reproduced herein with responses below each numbered comment. For your convenience, the Staff’s comments
from the Comment Letter are set forth below in bold font. Unless otherwise indicated, page references in the Staff’s comments refer
to the Offering Statement, and page references in the response refer to the Amendment. The responses provided herein are based on information
provided to Egan Nelson LLP by the Company. Capitalized terms used herein and not otherwise defined have the meaning given to them in
the Amendment.

May 9, 2025

Page 2

Draft Offering Statement on Form 1-A

Cover Page

 1. We note your response to prior comment 1, and that you are offering two distinct classes of securities.
As previously state, please specifically state the amount you are offering of each of the Class A-1 and Class A-2 notes.

Response: The Company has added disclosure
on the cover page of the offering circular and pages 5, 18 and 30 in response to the Staff’s comment.

Exhibits

 2. We refer to the Exhibit A-1 to the Note Purchase Agreement filed as Exhibit 3.2, and note that it states
the Class A-2 note will automatically roll over unless the holder elects to receive repayment of the principal and any accrued and unpaid
interest. We also note that your disclosure on page 3 states that the Class A-2 notes will automatically roll over unless the holder notifies
you pursuant to a written or electronic communication delivered at least 10 calendar days prior to the applicable maturity date. Please
revise your Note Purchase Agreement to be consistent with your disclosures regarding this requirement, or advise.

Response: The Company has revised the
terms of the Note Purchase Agreement so that they are consistent with the disclosure in the offering circular and has filed the revised
Note Purchase Agreement at Exhibit 3.2 to the Amendment.

General

 3. Please publicly file your Draft Offering Statement in accordance with Rule 252(d) of Regulation A.

Response: The Company has filed its correspondence
with the SEC as Exhibit 15 to the Amendment so as to comply with public filing requirements of Rule 252(d).

 4. We refer to the Class A-2 Notes, which you state will automatically roll over, and your revised disclosure
that the notes will automatically roll over unless the holder notifies you at least 10 calendar days prior to the applicable maturity
date that such holder elects to receive repayment. Please revise your disclosures as appropriate to explain that with respect to automatic
rollovers, you have the obligation to ensure that a non-accredited target invest is within the 10% investment limit set forth in Rule
251(d)(2)(i)(C). To the extent that there may be any risks that you fact from failures in these processes, consider whether any additional
disclosure, including risk disclosure, may be appropriate.

Response: The Company has added disclosure
on the cover page and page 30 of the offering circular in response to the Staff’s comment.

May 9, 2025

Page 3

If you have any questions or would
like further information concerning the Company’s responses to the Comment Letter, please contact me at (214) 628-9524.

Sincerely,

/s/ Kenneth L. Betts

Kenneth L. Betts

 cc: Mr. Todd B. Parriott

Connect Invest III LLC