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CORRESP
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CORRESP

 SIMPSON THACHER & BARTLETT
LLP

 900 G STREET, NW

WASHINGTON, D.C. 20001

TELEPHONE (202) 636-5500; FACSIMILE (202)
636-5502

September 2, 2025

 VIA EDGAR

Re:
 PIMCO Asset-Based Lending Company LLC

Registration Statement on Form 10-12G

Filed July 21, 2025

File No. 000-56764

Robert Arzonetti, Sarmad Makhdoom, Todd Schiffman, John Spitz

Securities and Exchange Commission

 Division of Corporation
Finance

 100 F Street, N.E.

 Washington, D.C. 20549

Ladies and Gentlemen:

 On behalf of PIMCO
Asset-Based Lending Company LLC (the “Company”), we are concurrently filing with the Securities and Exchange Commission (the “Commission”) Amendment No. 1 (“Amendment No. 1”) to the above-referenced
registration statement on Form 10-12G (the “Registration Statement”) filed with the Commission on July 21, 2025. The Company has revised the Registration Statement in response to the comment
letter from the staff (the “Staff”), dated August 18, 2024, relating to the Registration Statement (the “Comment Letter”) and to reflect certain other changes.

In addition, we are providing the following responses to the Comment Letter. To assist your review, we have retyped the text of the
Staff’s comments in italics below. Page references in the text of this letter correspond to the pages of Amendment No. 1. Unless otherwise defined below, terms defined in Amendment No. 1 and used below shall have the meanings given
to them in Amendment No. 1. The responses and information described below are based upon information provided to us by the Company.

 General

1.
 Please provide supplementally a more detailed description and explanation of the proposed ownership
structure of Series I and Series II. To the extent that your Investment Company Act status analysis depends on Series I and/or Series II being “majority owned subsidiaries” within the meaning of Section 3(a)(2) of the Investment
Company Act, please provide the relevant legal analysis. To the extent that a more detailed corporate structure chart may clarify these relationships, please feel free to provide one supplementally.

 BEIJING
 BRUSSELS  HONG KONG  HOUSTON  LONDON  LOS ANGELES  PALO ALTO
 SÃO PAULO  TOKYO  WASHINGTON, D. C.

Securities and Exchange Commission

September 2, 2025

 In response to the Staff’s comment, the Company notes that neither Series I nor Series
II is a “majority-owned subsidiary” of the Company. As explained on page 2 of the Registration Statement, the Company is organized as a Series LLC pursuant to the Delaware LLC Act and is comprised of Series I and Series II, each of which
issues their own securities and other liabilities and holds their own pool of segregated assets. Moreover, each Series has elected a different tax classification for U.S. federal income tax purposes. Series I has elected to be treated as a
corporation for U.S. federal income tax purposes and Series II is intended to be treated as a partnership for U.S. federal income tax purposes. Under Delaware law, to the extent the records maintained for a Series account for the assets
associated with such Series separately from the other assets of the Company or any other Series, the debts, liabilities, obligations and expenses incurred, contracted for or otherwise existing with respect to such Series are segregated and
enforceable only against the assets of such Series and not against the assets of the Company generally or any other Series.

 Series I and
Series II are expected to acquire, directly or indirectly, the same portfolio of Portfolio Assets through jointly held subsidiaries. With respect to each subsidiary that will hold assets, Series I and Series II will each (directly or indirectly) co-control the subsidiary, either as a co-general partner or an owner of exactly 50% of the subsidiaries’ outstanding voting securities. Each of those holding
subsidiaries will then make the types of investments described in the Company’s disclosure. Each Series’ respective economic exposure to the joint held subsidiaries is based on the relative amount of capital invested into each
Series at that moment and will be continually rebalanced inflows and outflows based on subscriptions and repurchases.

 The principal
difference between the two series is that certain holdings will be held through certain intermediary entities organized and taxed as corporations in order to provide the desired tax-reporting outcome to the
respective Series’ investors.

 Business Overview, page 1

2.
 Please expand your business section to state clearly if you have not yet begun operations and to include a
plan of operations for the next twelve months. In the discussion of your planned activities, include specific information regarding material events or steps required to pursue your planned activities, including any contingencies such as raising
additional funds.

 2

Securities and Exchange Commission

September 2, 2025

 In response to the Staff’s comment, the Company has revised its disclosure on page 1 to
provide additional information regarding the Company’s commencement and plan of operations for the remainder of the next twelve months as shown below (the text highlighted in
blue is newly added text):

 “The Company’s strategy is
structured to offer access to differentiated Asset-Backed Instruments, including consumer loans (e.g., student loans, auto loans, credit card receivables and mortgages), non-consumer loans (e.g., nonperforming loan financing, trade financing,
asset-based lending, royalties, small and medium-sized enterprise lending and risk transfer) and annuities and other insurance or reinsurance-related assets (collectively, the “Insurance Assets”), as well as select Platform
Acquisitions (as defined below) of specialty lenders, servicers, insurers, or reinsurers. The Company is expected to acquire primarily private income-producing assets from the aforementioned areas. The Company will principally seek to acquire (or
otherwise gain exposure to) individual income streams where risk of capital loss is deemed low or in pools of loans where returns adjusted for expected losses are attractive, even under stress scenarios. Over the long term, the returns of the
Company’s strategy are expected to consist of a combination of capital gains and income. The Company commenced its operations in July 2025. For the next twelve
months, the Company plans to continue to acquire Portfolio Assets using proceeds of subscriptions from the Shareholders, including the Seed Investor (as defined below).”

 Compensation of the Operating Manager, page 11

3.
 Please revise to summarize the management fee and performance allocation features, which are currently
described using many defined terms. For example, consider providing a table summarizing all possible compensation. To the extent management fees or performance allocation features include non-industry terms,
please revise to clarify.

 In response to the Staff’s comment, the Company has added a table summarizing
various fees and compensation on page 11.

 Share Repurchases, page 14

4.
 Please provide us with your analysis as to the applicability of the tender offer rules, including Rule 13e-4 and Regulation 14E, to your redemption program.

 Tender Offer Rules

 The Company acknowledges that it is responsible for analyzing the applicability of the tender offer rules, including Rule 13e-4 and Regulation 14E under the Securities Exchange Act of 1934, as amended (the “Exchange Act”), to its share repurchase plan. The Company believes that its share repurchase plan is not an
“issuer tender offer” subject to the tender offer rules, including Rule 13e-4 and Regulation 14E, under the Exchange Act. This conclusion is based on an analysis of the factors identified in
Wellman v. Dickinson,1 and applied in subsequent cases by the SEC and the Staff in determining what constitutes an “issuer tender offer” for purposes of the tender offer rules
under the Exchange Act.

1
 Wellman v. Dickinson, 475 F. Supp. 783 (S.D.N.Y. 1979).

 3

Securities and Exchange Commission

September 2, 2025

 As discussed in more detail below, the Company believes that repurchases of Shares pursuant
to its share repurchase plan do not implicate the concerns that the tender offer rules are intended to address. The purpose of the Company’s share repurchase plan is to provide Shareholders with ongoing liquidity. The terms of the share
repurchase plan will be fully disclosed to potential investors prior to the purchase of the Company’s Shares. Shareholders will be notified of the most recent quarterly transaction price and net asset value (“NAV”) per Share for
each type of Shares through the Company’s website and toll-free information line, and/or through current or periodic reports filed by the Company. Shareholders will be given sufficient time after the transaction price is made available to
submit their repurchase request or, if they had previously submitted their repurchase request, to withdraw such request if desired. The terms of the Company’s share repurchase plan, including full disclosure of the time in which to make
decisions, withdrawal rights, and proration in the event a repurchase offer is oversubscribed, collectively reduce pressure on Shareholders and mitigate the concerns that the tender offer rules were intended to address. Because the share repurchase
plan is not an “issuer tender offer” based on an analysis of the Wellman factors, the structural protections generally afforded to Shareholders under the tender offer rules are unnecessary for the protection of investors.

Analysis of the Wellman Factors

An analysis of the Wellman factors demonstrates that the Company’s share repurchase plan should not be viewed as an “issuer
tender offer” subject to the tender offer rules under the Exchange Act. Set forth below is an application of these factors to the share repurchase plan.

(i) Active and widespread solicitation of public stockholders for the Shares of an issuer. The Company will not engage in an active and
widespread solicitation for the repurchase of its Shares. The share repurchase plan will be described in the Company’s private placement memorandum (“PPM”), and any communications to Shareholders identifying changes to the plan
will be communicated through supplements to the PPM, current or periodic reports filed by the Company with the SEC, a press release and/or via the Company’s website. The Company respectfully submits that this disclosure is required by the
Exchange Act and is provided to make Shareholders aware of the plan’s existence, rather than to solicit the repurchase of Shares. The Company will not make any other significant public communications about the share repurchase plan except as
contained in or related to the PPM and its supplements, offering materials used in connection with the private placement of the Company’s Shares, required communications in periodic and current reports filed under the Exchange Act, the
dissemination of the quarterly transaction price and NAV per Share of each type of Shares of each Series on the Company’s website and toll-free information line, and communications required by the plan itself. Shareholders who desire to have
all or a portion of their Shares repurchased by the Company will do so of their own volition and not at the behest, invitation or encouragement of the Company. The Company will not solicit or encourage Shareholders to request repurchase of their
Shares. The role of the Company in effectuating repurchases under the share repurchase plan will be ministerial and will merely facilitate the full or partial exit by Shareholders from their investment in the Company.

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Securities and Exchange Commission

September 2, 2025

 (ii) The offer to purchase is made at a premium over the prevailing market price. No
premium will be paid over the prevailing market price by the Company for any Shares repurchased. The repurchase price will be the quarterly transaction price for the type of Shares being repurchased, and the offering price will be the monthly
transaction price for each type of Shares, plus applicable selling commissions and dealer manager fees. Further, there will be no established regular trading market for the Company’s Shares. The share repurchase plan will be terminated in the
event the Company’s Shares are listed on a national securities exchange or included for quotation in a national securities market. Because there is no established trading market and the offering price and repurchase price each quarter are
equal (except that selling commissions and dealer manager fees are not included in the calculation of the repurchase price), this factor does not apply.

(iii) The solicitation is made for a substantial percentage of the issuer’s stock. As noted above, the Company will not actively
solicit repurchases under the share repurchase plan. The share repurchase plan limits repurchases in any calendar quarter to 5% of the Company’s aggregate NAV (computed collectively across both Series) as of the last day of the previous
calendar quarter. The Company respectfully submits that the presence of such limitations means there is no reasonable likelihood that the share repurchase plan will have the effect of the Company repurchasing a “substantial percentage”
of its Shares in any quarter.

 As noted above, the Company’s share repurchase plan provides Shareholders with a means of liquidity in
respect of their investment in the Company. Accordingly, the Company respectfully submits that its share repurchase plan does not exist for the same reasons that issuers typically conduct tender offers. The Company intends to continuously raise
capital through a continuous private offering and use the net proceeds to acquire, own and control Portfolio Assets. Repurchasing Shares decreases funds available for such acquisitions and reduces the Company’s aggregate NAV, which creates a
disincentive for the Company to repurchase Shares.

 (iv) The terms of the offer are firm, rather than negotiable. The terms of the
Company’s share repurchase plan are firm with respect to the process by which Shareholders may request repurchases. While the repurchase price is not negotiable, it is not fixed at the same amount for the duration of the Share repurchase plan,
but rather it is determined each quarter, under normal circumstances based on the prior quarter’s NAV per Share determined using an established methodology. The Company believes, however, that this feature is not indicative of a tender offer
because the firmness of the terms of the share repurchase plan will not increase pressure on Shareholders to request repurchase of their

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Securities and Exchange Commission

September 2, 2025

Shares, as repurchases will be made at the applicable NAV per Share. The pressure on Shareholders that Rule 13e-4 attempts to reduce is that which is
caused by “a high premium with a threat that the offer will disappear within a certain time.”2 Where these factors exist, firmness of the terms of the offer may have the effect of
exacerbating the coercive pressure on Shareholders. However, as previously discussed, the Company’s share repurchase plan will not offer Shareholders a premium for their Shares and the Company intends that the share repurchase plan will exist
indefinitely (subject to the authority of the Company’s Board in its reasonable discretion to suspend the plan under specified circumstances or to make modifications to promote its proper and fair operation).

Additionally, the Company believes that NAV-based pricing for its repurchase program should have the
effect of mitigating pressure because Shareholders will know that they can request to have their Shares repurchased by the Company at the end of any quarter, under normal circumstances at the prior quarter’s NAV per Share. In a typical tender
offer, the issuer conceivably has both an incentive and the ability to set the offer price at a level