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Lincoln Partners Group Royalty Fund

 Phone: 484-583-8711

Email: sam.goldstein@lfg.com

 Lincoln Financial Group

150 N. Radnor Chester Rd.

 Radnor, PA
19087

 VIA EDGAR

September 22, 2025

 Samantha Brutlag, Esq.

John Kernan

 Brian Szilagyi

Division of Investment Management 

 Securities and Exchange
Commission

 100 F Street, N.E.

 Washington, D.C. 20549-4644

RE:

Registrant:

Lincoln Royalties Income Fund, LP (the “Trust”)

File Nos.:

File Nos. 333-285895 and 811-24065

Fund:

Lincoln Partners Group Royalty Fund (the “Fund”)

To the above-named Securities and Exchange Commission staff:

This letter responds to your comments, provided via phone on August 4, August 19, and September 22, 2025, to the Trust’s amended
registration statement filed on Form N-2 on July 28, 2025.

 The following are your comments and the
Trust’s responses.

1.
 Disclose the purpose of investing in underlying private funds (“UPFs”) that rely on 1940 Act
Sections 3(c)(1) or 3(c)(7); that the Fund may invest more than 15% of its assets in UPFs; and that such funds may charge performance and other administrative and management fees.

RESPONSE: The Fund has revised the disclosure as follows (new language underlined):

Royalties Primary Fund Investments and Secondary Fund Investments. To gain exposure to royalties
investments, the Fund may invest up to 70% of its assets in Royalties Funds, which are common vehicles for making royalty investments. Royalties Funds include private investment vehicles, such as “hedge funds” and “private equity
funds,” that typically offer their securities privately and are not registered as investment companies under the 1940 Act. These funds may charge performance and other administrative and management fees. The Fund may invest
more than 15% of its assets in underlying funds that are not registered as investment companies under the 1940 Act, in reliance on exemptions provided by Sections 3(c)(1) and 3(c)(7) of the 1940 Act.

Royalties primary fund investments are interests or investments in newly established royalties funds. Due to the limited
windows of opportunity for making primary fund investments in particular funds, strong relationships with leading firms are highly important for primary fund investors.

 Phone: 484-583-8711

Email: sam.goldstein@lfg.com

 Lincoln Financial Group

150 N. Radnor Chester Rd.

 Radnor, PA
19087

 Royalties secondary fund investments are interests in existing royalties
funds that are acquired in privately negotiated transactions, typically after the end of the royalties fund’s fundraising period. Secondary fund investments mean buying a stake in a fund after capital has already been raised through a private
deal, which may allow secondary fund investments to avoid — or greatly shorten — an early-stage dip in returns (the “J-curve”) that new, primary fund investments often experience. In
addition, secondaries typically provide earlier distributions than primaries and may provide valuable arbitrage opportunities for sophisticated investors. The ability to source and value potential investments is crucial for success in secondary fund
investing, and the nature of the process typically requires significant resources. As a result, generally only very large and experienced investors are active secondary market participants.

When evaluating potential Royalties Fund investments, the Sub-Adviser considers a
number of factors, including (but not limited to) the fund’s investment objectives and policies, the management team and its track record, the size of the fund, the nature of other investors in the fund, the returns target, the risk profile,
existing investments (where relevant) and the competitor landscape. The Sub-Adviser typically conducts investment process-related due diligence that includes commercial, technical, legal and tax due diligence,
which may be obtained with the assistance of third party diligence providers.

 In addition, under the heading
“Royalty Securitizations”, the following sentence has been added: “The Fund may invest in special purpose entities to gain exposure to royalty streams related to various industries.”

With respect to the response to previous Comment 14:

2.
 Disclose all material costs, strategies, and risks, as well as the investment process-related due diligence
practices conducted by the Fund’s adviser or sub-adviser when evaluating private fund investment opportunities (including investment, operational, legal, and as applicable, tax considerations).

 RESPONSE: With respect to material costs, strategies and risks, the Fund has added disclosure
stating that Royalties Funds investments may impact the strategies, risks and costs of and for the Fund itself, in addition to the following text:

Nature of Royalties Fund Investments. A Royalties Fund’s investments may involve highly speculative investment
techniques, highly concentrated portfolios, control and non-control positions and/or illiquid investments. There can be no assurance that (i) the Royalties Fund will have any profits, (ii) cash will
be available for distributions, (iii) the income of the Royalties Fund will exceed its expenses, (iv) the net asset value of the Royalties Fund will increase and (v) the Fund will not sustain a total loss of its investment in the
Royalties Fund. In addition, private equity securities generally represent the most junior position within an issuer’s capital structure and are therefore subject to the greatest risk of loss. Targeted returns will reflect the assumed level of
risk, but there can be no assurance that the

 Phone: 484-583-8711

Email: sam.goldstein@lfg.com

 Lincoln Financial Group

150 N. Radnor Chester Rd.

 Radnor, PA
19087

Royalties Fund will be adequately compensated for risks taken. The Royalties Fund would not typically receive interim cash dividends or other distributions on its private equity investments
during its holding period, but would realize its entire return upon eventual redemption or sale. The timing of ultimate realization is highly uncertain, as there can be no assurance that the issuer will be able to generate sufficient cash to redeem
them, and these securities will have no readily available market for liquidity. As a result, the holding period for these securities may be lengthy.

Expenses. Shareholders will effectively bear two layers of expenses: expenses of the Fund and indirect expenses
of the interests in the Royalties Funds. The indirect expenses of the interests in the Royalties Funds may adversely impact the Fund’s performance. A Shareholder in the Fund that meets the eligibility conditions imposed by one or more
Royalties Funds, including minimum initial investment requirements that may be substantially higher than those imposed by the Fund, could potentially invest directly in Royalties Funds. By investing in the Royalties Funds through the Fund, a
Shareholder in the Fund will bear a portion of the Investment Management Fee and other expenses of the Fund. Additionally, Royalties Funds generally charge asset-based fees and incentive fees (which are determined by the income and/or capital gains
generated by the Royalties Fund) that may be higher than those of other types of securities, which may adversely affect the Royalties Funds’ performance. There is a possibility that certain of the Royalties Funds may receive performance fees,
even if the performance of other Royalties Funds – or the overall performance of the Fund itself – is negative (i.e., “netting risk”).

With respect to investment process-related due diligence, the following text was added:

Due diligence and selection of investments

The Sub-Adviser follows a structured five-step process to source, evaluate, select
and monitor investments for the Fund. The Sub-Adviser’s investment professionals are involved throughout the process and draw on the significant investment resources and insight available through the Sub-Adviser’s affiliates, who collectively employ more than 1,800 people across a worldwide network of offices. The Sub-Adviser’s investment committee is
responsible for the portfolio plan and for final investment decisions.

 (1)  Deal generation. The Sub-Adviser typically identifies prospective investments from multiple sources, the most important of which is a global network of relationships across the royalties industry. Built through the investment activities
of the Sub-Adviser and its affiliated companies, this network has a historically proven track record of generating high volumes of deal flow. In particular, the
Sub-Adviser believes the broad scope of its royalties investment activities provides a competitive advantage for deal generation, enabling it to access attractive opportunities in local markets around the
world.

 (2)  Pre-selection. The initial screening process for
royalties investment

 Phone: 484-583-8711

Email: sam.goldstein@lfg.com

 Lincoln Financial Group

150 N. Radnor Chester Rd.

 Radnor, PA
19087

opportunities is typically based on a management presentation or an introductory meeting. For opportunities that pass the Sub-Adviser and its
affiliates’ minimum requirements, a due diligence deal team is assigned to evaluate the opportunity in detail.

(3)  Due diligence. The due diligence process involves a detailed analysis of various aspects of each
opportunity, including both qualitative and quantitative assessments. Various proprietary tools and databases are used to better understand market trends, potential return scenarios and/or the historical or anticipated sources of value creation for
an investment. Evaluations are generally based on information such as industry dynamics, competitive positioning, financial analysis, comparable analysis, interviews with key personnel, on-site visits,
reference calls, third-party consultant reports (for the commercial and technical due diligence) and/or track record analysis. The Sub-Adviser may, based on the results of such analysis, decline the
opportunity, request additional information, or approve subject to tax and legal due diligence.

 (4)  Tax and
legal assessment. In conjunction with the commercial and technical due diligence process, the tax treatment and legal aspects of the investment are considered (this can include anti-money laundering, regulatory, contractual and intellectual property
topics). Based on this analysis and the findings of external professional advisers, the Sub-Adviser’s and/or its affiliates’ internal legal and investment teams seek to negotiate the terms and
conditions of the investment. After resolving all open issues and negotiating terms, a final “investment recommendation” is prepared and the Sub-Adviser finally approves or declines the investment.

 (5)  Portfolio monitoring. Post-investment, the Sub-Adviser seeks to
monitor the Fund’s portfolio through regular interaction with the counterparts of our royalty investments. This interaction facilitates on-going portfolio analysis and a proactive approach to addressing
any new opportunities or issues that may arise.

 In addition, please see disclosure added in response to Comment 1 above.

3.
 Disclose any associated risks that may arise with more volatile or speculative investments, conflicts of
interest, and the liquidity of the private funds’ underlying investments.

 RESPONSE: With
respect to risks that may arise with more volatile or speculative investments, the following disclosure has been added:

A Royalties Fund’s investments may involve highly speculative investment techniques, highly concentrated portfolios,
control and non-control positions and/or illiquid investments. There can be no assurance that (i) the Royalties Fund will have any profits, (ii) cash will be available for distributions,
(iii) the income of the Royalties Fund will exceed its expenses, (iv) the net asset value of the Royalties Fund will increase and (v) the Fund will not sustain a total loss of its investment in the Royalties Fund. In addition, private
equity securities generally represent the most junior position within an issuer’s capital structure and are therefore subject to the greatest risk of loss. Targeted returns will reflect the assumed level of risk, but there can be no assurance
that the Royalties Fund will be adequately compensated

 Phone: 484-583-8711

Email: sam.goldstein@lfg.com

 Lincoln Financial Group

150 N. Radnor Chester Rd.

 Radnor, PA
19087

for risks taken.

 With respect to conflicts of interest, the
following disclosure has been added:

 The Adviser and Sub-Adviser may face
conflicts of interest in overseeing the valuation of the Royalties Funds investments, as their value will affect their compensation. Moreover, although the Sub-Adviser will periodically review Royalties Funds
valuation methods and inputs, including at initial purchase, the Fund will not generally have sufficient information in order to be able to confirm or review the accuracy of valuations provided. A Royalties Fund manager’s information could be
inaccurate due to fraudulent activity, misvaluation or inadvertent error. In any case, the Fund may not uncover errors for a significant period of time. Even if the Fund sells its interests in such a Royalties Fund, the Fund may be unable to sell
such interests quickly, if at all, and could therefore be obligated to continue to hold such interests for an extended period of time. In such a case, the Royalties Fund manager’s valuations of such interests could remain subject to such fraud
or error, and the Adviser may, in its sole discretion, determine to discount the value of the interests or value them at zero. Situations involving uncertainties as to the valuations by Royalties Fund managers could have a material adverse effect on
the Fund if the Royalties Fund manager’s, the Adviser’s or the Fund’s judgments regarding valuations should prove incorrect. Prospective investors who are unwilling to assume such risks should not make an investment in the Fund.

 With respect to liquidity, the following disclosure has been added:

Shares of Royalties Funds are not publicly traded. As such, investments in Royalties Funds will be subject to legal and
other restrictions on resale or will otherwise be less liquid than investments in publicly traded securities. In addition, the Royalties Funds may limit or suspend their redemptions, impose lock-up periods,
withdrawal fees or other measures that impact liquidity. This lack of liquidity of Royalties Funds creates several risks:

•

 First, it makes it difficult for the Sub-Adviser to determine if the
Royalties Fund is accurately valuing its positions because of the uncertainty regarding the realization of the prices that are quoted if the Royalties Fund were to attempt to liquidate its portfolio at those prices.

•

 Second, it increases the risk that withdrawals from such Royalties Funds by other investors will cause reductions
in the net asset value of those Royalties Funds merely due to selling pressure, rather than a fundamental change in the investments themselves.

•

 Third, it increases the risk that a Royalties Fund will not honor the Fund’s liquidity expectations.
Royalties Funds have restrictions in their governing documents that limit the Fund’s ability to withdraw funds typically to calendar month or quarter ends (or less frequently) on significant prior notice, Royalties Funds may nevertheless be
unable to abide by these somewhat onerous liquidity provisions. A side effect of this inability to

 Phone: 484-583-8711

Email: sam.goldstein@lfg.com

 Lincoln Financial Group

150 N. Radnor Chester Rd.

 Radnor, PA
19087

withdraw from a Royalties Fund is the Sub-Adviser’s inability to re-allocate the Fund’s assets as
dynamically as the Sub-Adviser may otherwise desire. This limitation exists even when a Royalties Fund has not implemented a constraint on its expected liquidity. Given that, even in the best of times, these
Royalties Funds permit withdrawals only infreq