SecProbe.io

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 Jefferies LLC
520 Madison Avenue
New York, New York 10022
 Keefe, Bruyette & Woods, Inc.
787 Seventh Avenue
New York, New York 10019

 June 24, 2025

 VIA EDGAR

 U.S. Securities and Exchange Commission

 Division of Corporation Finance

 Office of Finance

 100 F Street, N.E.

 Washington, D.C. 20549-6010

 Attention:

 Madeleine Joy Mateo
 Todd Schiffman

 Joe Yeon Ahn
 Amit Pande

 Re:

 Jefferson Capital, Inc. (the "Company")

 Registration Statement on Form S-1, as
 amended (File No. 333-287488)
 Request for Acceleration of Effective Date

 Ladies and Gentlemen:

 As representatives of the several underwriters
of the proposed public offering of the Company's common stock by the Company and the selling stockholders, we hereby join the Company's
request that the effective date of the above-referenced Registration Statement be accelerated so that the above-referenced Registration
Statement will be declared effective at 4:00 pm (ET) on June 25, 2025, or as soon thereafter as is practicable.

 Pursuant to Rule 460 of the General Rules and
Regulations of the Securities and Exchange Commission under the Securities Act of 1933, as amended, we wish to advise you that we have
effected the following distribution of the Company's Preliminary Prospectus dated June 13, 2025, through the date hereof:

 Preliminary Prospectus dated June 13, 2025:

 Approximately 300 copies to prospective underwriters,
institutional investors, dealers and others.

 The undersigned advise that they have complied
and will continue to comply, and that they have been informed by the participating underwriters and dealers that they have complied with
and will continue to comply, with the requirements of Rule 15c2-8 under the Securities Exchange Act of 1934, as amended.

 [ Remainder of Page Intentionally Left Blank ]

 Very truly yours,

 As Representatives of the several Underwriters

 Jefferies LLC

 By:
 /s/ Michael Bauer

 Name: Michael Bauer

 Title: Managing Director

 [ Signature Page to Acceleration Request
by Underwriters ]

 Keefe, Bruyette & Woods, Inc.

 By:
 /s/ Victor Sack

 Name: Victor Sack

 Title: Managing Director, Head of Capital Markets

 [ Signature Page to Acceleration Request
by Underwriters ]

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 Jefferson Capital, Inc.
 600 South Highway 169, Suite 1575

 Minneapolis, Minnesota 55426

 June 24, 2025

 VIA EDGAR

 U.S. Securities and Exchange Commission
Division of Corporation Finance

 Office of Finance

 100 F Street, N.E.
Washington, D.C. 20549-6010

 Attention: Madeleine Joy Mateo

 Todd Schiffman

 Joe Yeon Ahn

 Amit Pande

 Re: Jefferson Capital, Inc.
 Registration Statement on Form S-1, as amended (File No. 333-287488)

 Request for Acceleration of Effective Date

 To the addressees set forth above:

 In accordance with Rule 461
under the Securities Act of 1933, as amended, Jefferson Capital, Inc. (the " Company ") hereby requests acceleration
of the effective date of the above-referenced Registration Statement on Form S-1, as amended (File No. 333-287488) (the
 " Registration Statement "). The Company respectfully requests that the Registration Statement become effective
as of 4:00 p.m., Eastern Time, on June 25, 2025, or as soon as practicable thereafter, or at such other time as the Company or its
legal counsel may request by telephone to the staff of the Division of Corporation Finance of the U.S. Securities and Exchange Commission
(the " Commission "). Once the Registration Statement has been declared effective, please orally confirm that
event with our counsel, Latham & Watkins LLP, by calling Erika L. Weinberg at (212) 906-1297.

 We understand that the staff
of the Commission will consider this request as confirmation by the Company that it is aware of its responsibilities under the federal
securities laws as they relate to the issuance of the securities covered by the Registration Statement. If you have any questions regarding
the foregoing, please contact Erika L. Weinberg of Latham & Watkins LLP at the number set forth above.

 Thank you for your assistance in this matter.

 Sincerely,

 Jefferson Capital, Inc.

 By:
 /s/ David Burton

 Name:
 David Burton

 Title:
 President and Chief Executive Officer

 cc: Christo Realov, Chief Financial Officer and Treasurer, Jefferson Capital, Inc.
 Matthew Pfohl, Esq., Chief Administrative Officer, General
Counsel and Secretary, Jefferson Capital, Inc.

 Marc D. Jaffe, Esq., Latham & Watkins LLP

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 1271 Avenue of the Americas

 New York, New York 10020-1401

 Tel: +1.212.906.1200 Fax: +1.212.751.4864

 www.lw.com

 FIRM / AFFILIATE OFFICES

 Austin
 Milan

 Beijing
 Munich

 Boston
 New York

 Brussels
 Orange County

 Century City
 Paris

 Chicago
 Riyadh

 Dubai
 San Diego

 June 13, 2025
 Düsseldorf
 San Francisco

 Frankfurt
 Seoul

 Hamburg
 Silicon Valley

 Hong Kong
 Singapore

 Houston
 Tel Aviv

 London
 Tokyo

 Los Angeles
 Washington, D.C.

 Madrid

 VIA EDGAR

 United States Securities and Exchange Commission
Division of Corporation Finance

 Office of Finance
100 F Street, N.E.

 Washington, D.C. 20549-6010

 Attention:
 Madeleine Joy Mateo

 Todd Schiffman

 Jee Yeon Ahn

 Amit Pande

 Re:
 Jefferson Capital, Inc. Amendment
 No. 1 to Registration Statement on Form S-1

 Filed May 23, 2025

 File No. 333-287488

 Ladies and Gentlemen:

 On behalf of Jefferson Capital, Inc. (the
 " Company "), we submit this letter in response to the comment received from the staff of the U.S. Securities
and Exchange Commission (the " Staff ") by letter, dated June 9, 2025 (the " Comment Letter "),
regarding the Company's Amendment No. 1 to the Registration Statement on Form S-1, as filed with the Staff on May 23,
2025 (the " Registration Statement ").

 The Company is concurrently publicly filing with
the Staff Amendment No. 2 to the Registration Statement on Form S-1 (" Amendment No. 2 "), which
reflects certain revisions to the Registration Statement in response to the Comment Letter, as well as certain other changes.

 For ease of review, we have set forth below the
comment of your letter in bold type followed by the Company's response thereto. Unless otherwise indicated, capitalized terms used
herein have the meanings assigned to them in Amendment No. 2 and all references to page numbers in such responses are to page numbers
in Amendment No. 2.

 June 13, 2025

 Page 2

 Amendment No. 1 to Registration Statement on Form S-1

 Portfolio Purchasing, page 74

 1. We note your response to prior comment 3 and your revised disclosures related to nonperforming, semi-performing and performing
loans and your statement that regardless of whether the portfolio consists of performing, semi-performing or nonperforming loans, all
still can be purchased credit deteriorated (PCD) loans. We also note your response to prior comment 6 that you determined the Conn's
portfolio purchase represented one collective pool with similar risk characteristics for your assessment of PCD assets. Considering your
disclosure on pages 18 and 134 that you plan to expand performing or semi-performing loan purchases in the United States, please
tell us and/or revise as appropriate to address the following:

 · Please clarify how you considered the guidance in ASC 326-20-30 in determining that the Conn's nonperforming, semi-performing,
and performing loans had similar risk characteristics at the date of acquisition.

 · Please quantify the recorded amounts at the date of acquisition for each of the three loan portfolios.

 · Please clarify how you determined that the 46.8% of loans acquired in the Conn's portfolio purchase, for which the borrower's
ability to make scheduled interest or principal payments was not in doubt, experienced a more-than-insignificant deterioration
in credit quality since origination at the time of acquisition.

 · Please quantify the portion of the 46.8% of loans acquired in the Conn's portfolio purchase that did not use the in-store
payment options prior to the Conn's bankruptcy.

 · Please tell us the possible impact on your financial statements at December 31, 2024 and March 31, 2025 if you determined
that the 46.8%, or another percentage, of loans acquired in the Conn's portfolio purchase did not meet the definition of purchased
financial assets with credit deterioration.

 Response:
The Company respectfully acknowledges the Staff's comment and submits to the Staff that the description of its purchasing activities
was insufficient, and the Company has updated its glossary on page vi to remove the separate definition of "semi-performing
loans," which is not currently tracked by the Company as a discrete category of portfolios and clarify that the Company's
references to "performing loans" pertain to a portfolio of loans that have not yet been charged-off by the credit originator
for accounting purposes, but generally exhibit a significant level of credit deterioration. In practice, it is possible for such performing
loans to be considered PCD assets under U.S. generally accepted accounting principles (U.S. GAAP). "Performing loans" with
significant credit deterioration is the only discrete category of loans that the Company accounts for separately from "nonperforming
loans," which consist primarily of loans that have been charged-off by the credit originator for accounting purposes, either by
reason of excessive delinquency or due to a consumer-initiated insolvency process. Typically, the Company purchases both performing loans
and nonperforming loans at significant discounts to par, which is indicative of significant credit deterioration on both pools of assets,
whether charged-off or not.

 To help clarify these points, the Company has also updated
pages 18, 74, and 134 to remove references to "semi-performing loans," which term was originally intended to highlight
that the category of loans that are considered not to be "non-performing loans" is broad and includes portfolios with significant
credit deterioration even if technically categorized by the Company as "performing loans." The Company believes that by simplifying
its disclosure to only refer to "nonperforming loans" and "performing loans," it can avoid inadvertent conflation
of terms and instead focus investors on Jefferson Capital's core business: acquiring credit deteriorated loans and receivables at
a discount. The Conn's Portfolio Purchase was a good example of the Company's core business as it acquired a non-performing
loan portfolio at less than 1% of par value and acquired the significantly credit deteriorated performing loan portfolio a 60% discount
to par.

 June 13, 2025
 Page 3

 In response to the specific requests included in the Staff's
comment, the Company respectfully advises the Staff as follows.

 How the Company Considered ASC 326-20-30 Guidance for
the Conn's Portfolio Purchase

 In connection with the Conn's Portfolio Purchase, the
Company considered ASC 326-20-30-2, which requires credit losses to be evaluated on a collective pool basis where similar risk characteristics
exist. It also considered ASC 326-20-55-5, which requires the following potential risk characteristics to be considered in determining
if financial assets should be evaluated on a collective pool basis: (i) credit scores, (ii) risk ratings or classifications,
(iii) financial asset type, (iv) collateral type, (v) size, (vi) interest rate, (vii) term, (viii) geography,
(ix) industry of the borrower, (x) vintage, (xi) historical or expected credit loss patterns, and (xii) reasonable
and supportable forecast periods. In considering such accounting guidance, the Company determined that the performing loans that had not
yet been charged-off underlying the Conn's Portfolios were appropriately grouped as a single pool based on common risk characteristics
that included those set forth in the table below:

 Characteristic
 Features

 Credit Score
 Substantially all subprime consumer credits without any clear delineations

 Risk Ratings of Classification
 Conn's did not update risk classifications for credit performance, and loans performed similarly across risk rating buckets

 Financial Asset Type

 1)     Installment
 loans
 2)     Receivables
 originated as revolving loans. However, these receivables had their revolving period suspended in June 2024 around the time of the
 bankruptcy filing and prior to the closing of the Conn's Portfolio Purchase, and the receivables were paying down and effectively
 operating as installment loans at the time we closed the Conn's Portfolio Purchase.

 All loans have a use of proceeds to finance the purchase of home goods
 sold through one of the Conn's owned stores

 Collateral Type
 All unsecured

 Size
 Similar average balances ($2,000) and similar original balances of ~$3,200

 Interest Rate
 Average APR of 32.1% with a range of 29% to 33%

 Original Term
 34 months with a tight distribution

 Geography
 Substantially all in U.S. Southeast

 Vintage
 Similar origination vintage years

 June 13, 2025
 Page 4

 Amounts Recorded at Date of Acquisition

 In connection with the Conn's Portfolio Purchase, the
Company used a simple brightline test to differentiate performing loans (loans that had not previously been charged off by Conn's)
from nonperforming loans (loans that had been previously charged off by Conn's) and evaluated these two pools separately. The Company
only allocated the purchase price between a portfolio of "nonperforming loans" and a portfolio of "performing loans."

 The Company determined that nonperforming loans had a different
risk profile than the rest of the portfolio. The Company allocated $12.0 million, or 4.9% of the Company's purchase price,
to approximately $1.5 billion in nonperforming loans that were charged-off by Conn's in accordance with their accounting policies,
and the Company evaluated such loans separately under ASC 326-20-30.

 The Company evaluated the rest of the Conn's Portfolios
as a single pool of loans under ASC 326-20-30 and determined they were all PCD loans, allocating $226.3 million, or 92.3% of the purchase
price, to these performing loans, with the rest of the purchase price allocated to cash and intangibles associated with the assembled
workforce. For reference, relative to $567 million of principal, this allocated purchase price represented a 60% discount to par. While
 "performing," when considered under a definition of performing loans that consists of loans that are not yet charged-off,
the loans were significantly credit deteriorated, as evidenced by the significantly discounted purchase price.

 The Company Determined the Performing Loan Portfolio Was
PCD:

 For
the group of loans that was not previously charged-off, which the Company calls "performing", the Company determined
that these loans were PCD. The Company had previously indicated that 53.2% of the performing loan portfolio was delinquent or recently
delinquent at the time of the Conn's Portfolio Purchase. The Company respectfully submits to the Staff that the Company did not
determine that for the other 46.8% of the loans acquired in the Conn's Portfolio Purchase "the borrower's ability to
make scheduled interest or principal payments was not in doubt." Rather, the Company advises the Staff that it previously indicated
that there was significant doubt that the borrowers for all loans would make payments on schedule, including the 46.8% that had not yet
become delinquent. The Company intended to indicate that the ability of borrowers (generally) to make scheduled interest or principal
payments was in doubt. One piece of evidence for this doubt was that 53.2% were actively or had recently been delinquent. The Company
believed, however, that the remaining 46.8% of loans that were not delinquent also had significant doubt as to the ability of borrowers
to make payments and were evaluated as a single pool of assets with the 53.2%, and the Company did not intend to suggest otherwise.

 While 46.8% of the loans were not delinquent at the time
of acquisition the Company concluded the pool of performing loans displayed more than insignificant credit deterioration from the time
of origination through the acquisition date due to the following factors:

 (i) the fact that a significant amount of the payments received historically were through Conn's stores, which were recently closed;

 June 13, 2025
 Page 5

 (ii) the credit originator filing for bankruptcy can negatively affect the willingness of borrowers to repay loans received from that originator;

 (iii) the Company expected a further disruption in credit performance and related significant increase in delinquencies from the transition
of servicing to the Company;

 (iv) roll-rates, or the tendency of new loans to become delinquent, had significantly worsened; and

 (v) the likelihood of newly originated loans to become charged-off had significantly increased, as exhibited by the successive significantly
steepening vintage curves (as shown in both charts below). The steepening trend of these charts indicate a significant deterioration in
credit performance since the time of origination as loans that were newly originated have been increasingly likely to default despite
as well over 40% of the original principal balances of newly originated loans has ultimately been written off, and the trend was worsening.

 June 13, 2025
 Page 6

 At the time of the Conn's Portfolio Purchase, the Company
estimated that a majority of the 46.8% that had not been delinquent when the Conn's Portfolio Purchase closed would eventually go
delinquent . The Company believes all of these factors demonstrate that the portfolio as a whole was significantly credit deteriorated
and there was significant doubt regarding the ability of all borrowers to make payments, which is evidenced in the 60% discount to par
paid for these loans.

 Quantifying the Portion of the 46.8% of Loans Acquired
in the Conn's Portfolio Purchase that Did Not Use the In-Store Payment Options Prior to the Conn's Bankruptcy

 The Company respectfully advises the Staff that the Company
does not have an ability to track distinct accounts which historically made payments via particular payment methods, so it is unable to
quantify the portion requested by the Staff as the Company can only quantify total amount of payment by payment channel.

 However, the Company believes that the fact that 25% of total
instalment loan payments and 60% of revolving loan payments were made by in-store payment options, when that payment channel was available,
demonstrates that a significant proportion of the accounts that were making payments relied on the stores to do so. These are proportions
of total payments received, and the Company believes they are therefore more likely to be skewed significantly to the accounts that were
current and might have been making payments, as opposed to accounts that were delinquent, and therefore, much less likely to have made
payments.

 Conclusion

 As detailed above, the Company determined that the 46.8%
of loans that were current when the Conn's Portfolio Purchase closed exhibited, as a single pool portfolio, significant credit
deterioration and otherwise had similar risk characteristics outlined under ASC 326-20-55-5 with the 53.2% of loans that were delinquent
at the time the purchased closed. As such, the Company determined the portfolio should be evaluated as a single group under ASC 326-20-30-2.

 * * *

 June 13, 2025
 Page 7

 We hope the foregoing answer is responsive to your
comment. Please do not hesitate to contact me by telephone at (212) 906-1281 with any questions or comments regarding this correspondence.

 Very truly yours,

 /s/ Marc D. Jaffe

 Marc D. Jaffe

 of LATHAM & WATKINS LLP

 cc:
 (via email)

 David Burton, President and Chief Executive Officer, Jefferson Capital, Inc.

 Christo Realov, Chief Financial Officer and Treasurer, Jefferson Capital, Inc.

 Matthew Pfohl, Esq., Chief Administrative Officer, General Counsel and Secretary, Jefferson Capital, Inc.

 Erika L. Weinberg, Esq., Latham & Watkins LLP

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 June 9, 2025

David Burton
President and CEO
Jefferson Capital, Inc.
600 South Highway 169, Suite 1575
Minneapolis, MN 55426

 Re: Jefferson Capital, Inc.
 Amendment No. 1 to Registration Statement on Form S-1
 Filed May 23, 2025
 File No. 333-287488
Dear David Burton:

 We have reviewed your amended registration statement and have the
following
comment.

 Please respond to this letter by amending your registration statement
and providing
the requested information. If you do not believe a comment applies to your
facts and
circumstances or do not believe an amendment is appropriate, please tell us why
in your
response.

 After reviewing any amendment to your registration statement and the
information
you provide in response to this letter, we may have additional comments. Unless
we note
otherwise, any references to prior comments are to comments in our May 19, 2025
letter.

Amendment No. 1 to Registration Statement on Form S-1
Portfolio Purchasing, page 74

1. We note your response to prior comment 3 and your revised disclosures
related to
 nonperforming, semi-performing and performing loans and your statement
that
 regardless of whether the portfolio consists of performing,
semi-performing or non-
 performing loans, all still can be purchased credit deteriorated (PCD)
loans. We also
 note your response to prior comment 6 that you determined the Conn's
portfolio
 purchase represented one collective pool with similar risk
characteristics for your
 assessment of PCD assets. Considering your disclosure on pages 18 and
134 that you
 plan to expand performing or semi-performing loan purchases in the
United States,
 please tell us and/or revise as appropriate to address the following:
 June 9, 2025
Page 2

 Please clarify how you considered the guidance in ASC 326-20-30 in
determining
 that the Conn s nonperforming, semi-performing, and performing loans
had similar
 risk characteristics at the date of acquisition.
 Please quantify the recorded amounts at the date of acquisition for
each of the three
 loan portfolios.
 Please clarify how you determined that the 46.8% of loans acquired
in the Conn s
 portfolio purchase, for which the borrower s ability to make scheduled
interest or
 principal payments was not in doubt, experienced a
more-than-insignificant
 deterioration in credit quality since origination at the time of
acquisition.
 Please quantify the portion of the 46.8% of loans acquired in the
Conn s portfolio
 purchase that did not use the in-store payment options prior to the
Conn's bankruptcy.
 Please tell us the possible impact on your financial statements at
December 31, 2024
 and March 31, 2025 if you determined that the 46.8%, or another
percentage, of loans
 acquired in the Conn s portfolio purchase did not meet the definition
of purchased
 financial assets with credit deterioration.
 Please contact Jee Yeon Ahn at 202-551-3673 or Amit Pande at
202-551-3423 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Madeleine Joy Mateo at 202-551-3465 or Todd Schiffman at 202-551-3491
with any
other questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Finance
cc: Erika Weinberg, Esq.
</TEXT>
</DOCUMENT>

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 1271 Avenue of the Americas

 May 23, 2025

 New York, New York 10020-1401

 Tel: +1.212.906.1200 Fax: +1.212.751.4864

 www.lw.com

 FIRM / AFFILIATE OFFICES

 Austin
 Milan

 Beijing
 Munich

 Boston
 New York

 Brussels
 Orange County

 Century City
 Paris

 Chicago
 Riyadh

 Dubai
 San Diego

 Düsseldorf
 San Francisco

 Frankfurt
 Seoul

 Hamburg
 Silicon Valley

 Hong Kong
 Singapore

 Houston
 Tel Aviv

 London
 Tokyo

 Los Angeles
 Washington, D.C.

 Madrid

 VIA EDGAR

 United States Securities and Exchange Commission
Division of Corporation Finance

 Office of Finance
100 F Street, N.E.

 Washington, D.C. 20549-6010

 Attention:

 Madeleine Joy Mateo

 Todd Schiffman
 Jee Yeon Ahn
 Amit Pande

 Re:
 Jefferson Capital, Inc. Amendment No. 2 to Draft Registration Statement on Form S-1

Submitted May 5, 2025
CIK No. 0002046042

 Ladies and Gentlemen:

 On behalf of Jefferson Capital, Inc. (the
 " Company "), we submit this letter in response to the comments received from the staff of the U.S. Securities
and Exchange Commission (the " Staff ") by letter, dated May 19, 2025 (the " Comment Letter "),
regarding the Company's Draft Registration Statement on Form S-1, as submitted to the Staff on a confidential basis pursuant
to Title I, Section 106 under the Jumpstart Our Business Startups Act on May 5, 2025 (the " Draft Registration Statement ").

 The Company is concurrently publicly filing with
the Staff the Registration Statement on Form S-1 (the " Registration Statement "), which reflects certain
revisions to the Draft Registration Statement in response to the Comment Letter as well as certain other changes.

 For ease of review, we have set forth below the
comment of your letter in bold type followed by the Company's response thereto. Unless otherwise indicated, capitalized terms used
herein have the meanings assigned to them in the Registration Statement and all references to page numbers in such responses are
to page numbers in the Registration Statement.

 May 23, 2025

 Page 2

 Amendment No. 2 to Draft Registration Statement on Form S-1

 Risk Factors

 Our use of machine learning and AI technologies, page 44

 1. We note from your response to comment 1 that you adopted a governance policy for the use of artificial intelligence. Please disclose
the substance of your response in this risk factor.

 Response: The Company respectfully acknowledges the
Staff's comment and has updated the disclosure on pages 45 and 141.

 Unaudited Pro Forma Consolidated Financial Information, page 64

 2. We note your disclosure on page F-40, and elsewhere, regarding transactions for the issuance of Senior Notes on May 2,
2025. Similarly, we note that you include disclosure within footnote 2 on page 60 that it appears you intend to include those notes
in your Capitalization table. Please clarify and tell us whether you have included or intend to include pro forma information and adjustments
that give effect to the Senior Notes in the May 2, 2025 transaction. Refer to 11-01(a)(8) of Regulation S-X.

 Response : The Company respectfully acknowledges the
Staff's comment and advises the Staff that the Company does not intend to include pro forma financial information and adjustments
to give effect to the above-referenced Senior Notes in the section titled "Unaudited Pro Forma Consolidated Financial Information."
The Company instead intends to clearly present such impact in the capitalization table included in the section titled "Capitalization."

 The proceeds from the Senior Notes issued on May 2,
2025 were used to pay down the Revolving Credit Facility, resulting in the transaction being leverage neutral. Because the Senior Notes
and the Revolving Credit Facility are consolidated on the balance sheet within the "Notes payable, net" line item, the Company
believes the impact on the balance sheet from issuing the notes was immaterial to the overall balance sheet of the Company, except where
it is presented further broken out into as in the "Capitalization" section.

 The interest rate of the Senior Notes of 8.25% was not materially
higher than the Revolving Credit Facility pricing such that the income statement impact of the notes would also not be material.

 Portfolio Purchasing, page 71

 3. We note your disclosure that you occasionally purchase portfolios that are semi-performing and performing. Please define "semi-performing"
portfolios and expand your discussion to explain how semi-performing loans differ from performing or nonperforming loans. Fully explain
how you evaluate loan performance (e.g., credit quality assessment) and determine appropriate loan classification as nonperforming, semi-performing,
and performing loans. Also, please quantify, here or in another appropriate location, the amount of semi-performing and performing portfolios
for each of the periods presented or state that they are immaterial.

 Response : The Company respectfully acknowledges the
Staff's comment and has provided definitions for nonperforming, performing and semi-performing to the Glossary. The Company also
updated the disclosure in the section titled "Management's Discussion and Analysis of Financial Condition and Results of Operations-Our
Business Model - Portfolio Purchasing" on pages vi and vii and 74.

 May 23, 2025

 Page 3

 The Company advises the Staff that nonperforming loans consist
primarily of loans that have been charged-off by the credit originator for accounting purposes. Typically, a charge-off can be recognized
either by reason of excessive delinquency or due to a consumer-initiated insolvency process. If the former, the Company would consider
the loan within its distressed business line, and if the latter, the Company would consider the loan within its insolvency business line.
When a credit originator charges-off a loan for reason of excessive delinquency varies as some banks charge-off loans in as little as
90 or 120 days, whereas other credit originators can charge-off loans only after 180 days or even 360 days of contractual delinquency.

 The Company occasionally evaluates and bids for portfolios
that are purely performing loans where delinquencies are modest and credit performance is normal, and the credit originator is choosing
to sell the loans because they are exiting a business line or a strategy. More common and a larger opportunity for the Company are situations
where there is a high level of delinquency or other form of credit deterioration in a portfolio, such as restructurings of the loans or
other forms of modification, even if the loans have not yet been charged-off, though many will be after the passage of incremental months.
In these cases, the Company finds that its expertise in evaluating and managing charged-off accounts allows the Company to confidently
manage a portfolio that has a higher level of credit risk than a buyer without that level of expertise would be comfortable with. The
Company refers to these portfolios as semi-performing. Regardless of whether the portfolio consists of performing, semi-performing or
nonperforming loans, all still can be purchased credit deteriorated loans. Often credit deterioration may have precipitated the reason
for the loan sale, as was the case with Conn's Portfolio where credit deterioration contributed to the causes of its bankruptcy
filing. In such an instance, performing loans may be mixed with loans that are semi-performing or delinquent and restructured as well
as a significant amount of charged-off or nonperforming loans, as was also the case with Conn's, and with a high level of risk that
more of the current loans will become delinquent over time and eventually need to be charged-off. In these cases, the Company can offer
the seller the convenience of purchasing all its loan assets altogether.

 The Company considers the amount of performing and semi-performing
loans purchased to be immaterial in the periods indicated apart from the purchase of the Conn's Portfolio in December 2024.
Aside from the Conn's Purchase, the Company did not purchase any other portfolios in the year ended December 31, 2024 that
it considers to be semi-performing or performing, as all other accounts purchased in the year ended December 31, 2024 were previously
charged-off for reason of excessive delinquency or insolvency. In the year ended December 31, 2023, the Company purchased $8.4
million in portfolios that it considers to be semi-performing or performing, representing 1.6% of total purchases in the year ending December 31,
2023. In the three months ended March 31, 2025, the Company also purchased $4.3 million in portfolios that it considers to
be semi-performing or performing, representing 2.5% of total purchases in the three months ended March 31, 2025 which is not material.

 The Company regularly evaluates the opportunity to purchase
portfolios that include a mix of semi-performing and performing accounts, as well as nonperforming accounts, and that comprise all of
a credit originators loan assets and believes it will find attractive opportunities to make more purchases like these going forward.

 May 23, 2025

 Page 4

 Non-GAAP Financial Measures, page 74

 4. Please tell us your consideration to present the income tax effects related to your adjustments to calculate and present Adjusted
Net Income. Refer to Question 102.11 of the Non-GAAP Financial Measures Compliance & Disclosure Interpretations.

 Response : The Company respectfully acknowledges the
Staff's comment and advises the Staff that the income tax effects related to the adjustments to net income that are included in
adjusted net income are shown in the pro forma financial tables included within the Non-GAAP Financial Measures section on pages 80
and 81.

 Because the Company is not a C-corporation and does not recognize
U.S. income tax expense prior to the Reorganization, and because the adjustments relate to financial items realized through U.S. entities,
there are no income tax effects to the adjustments prior to considering the pro forma impact of the Reorganization.

 In the Reorganization, there will be a tax effect to each
of the adjustments to net income, and these are presented in the "Reorganization Adjustments" column for the year ended December 31,
2024 in the table shown on page80 and for the three months ended March 31, 2025 in the table shown on page 81. The adjustment
for Canaccede Exit Consideration will not have a tax effect as it is not considered to be tax deductible, and no tax deduction was included
for it in the tax effect included for the base net income shown in each table either.

 Results of Operations, page 79

 5. We note your disclosure on page 80 regarding total portfolio revenue trends. Please revise to provide a discussion of specific
revenue drivers and causes associated with changes in recoveries. Refer to Item 303(b)(2) of Regulation S-K.

 Response : The Company respectfully
acknowledges the Staff's comment and has updated the disclosure on pages 85, 90 and 97.

 Note 1. Organization, Description of Business and Summary of
Significant Accounting

 Policies, page F-19

 6. We note your disclosures
on page F-19 and also page F-22 that you have purchased performing receivable portfolios (i.e., Conn's) that exhibited more-than-insignificant
deterioration in credit quality at the time of acquisition and were accounted for as PCD assets under ASC 326. Further, your disclosure
on page F-19 indicates that you believe you will successfully collect a significant portion where the consumer will pay on a normal
schedule. Please provide us with an accounting analysis explaining the factors you considered, including but not limited to those described
in ASC 326-20-55-57 through 60, in your determination that these meet the definition of PCD.

 Response: The Company respectfully
acknowledges the Staff's comment, including analysis related paragraph ASC 326-20- 55-57 through 60. The Company determined the
Conn's portfolio purchase represented one collective pool with similar risk characteristics for purposes of assessing whether the
financial assets represent PCD assets as of the date of acquisition .

 In considering 55-57 through 60, the
following characteristics were identified as relevant to the Conn's portfolio purchase in concluding that the financial assets represent
PCD assets:

 a. Financial
assets that are delinquent as of the acquisition date;

 b. Financial
asset that have been downgraded since origination; and

 c. Financial
assets that have been placed on non-accrual status.

 May 23, 2025

 Page 5

 In evaluating the Conn's portfolio
total unpaid balances associated with receivables acquired were $567 million with a purchase price of $226 million. The significant discount
paid for the pools is an indicator of significant deterioration of the portfolios acquired as evidenced with more than half of the borrowers
being delinquent or having experienced an adverse credit event at the time of acquisition The discount of $340 million to par was attributable
primarily to the credit mark of $251 million with the remaining portion attributable to the interest mark of $89 million.

 In further consideration of ASC 326-20-55-4,
the following criteria were considered in our analysis of the purchased portfolio.

 ASC 326-20-55-4 a) The borrower's
financial conditions, credit rating, credit score, asset quality, or business prospects and borrower's ability to make scheduled
interest or principal payments.

 At the time of acquisition, the borrower's
ability to make scheduled interest or principal payments was in doubt as 53.2% of the population was delinquent, had been delinquent at
some point in time, the consumer credit score decreased from origination, or the terms of the loans were modified for non-payment. With
the closing of the stores limiting the payment channels previously available to the consumers, this would further reduce the ability of
the consumer to make scheduled interest or principal payments.

 ASC 326-20-55-4 f) The volume and
severity of past due financial assets and the volume and severity of adversely classified or rated financial assets.

 From late 2020 to first quarter 2024
before Conn's bankruptcy filing, charge-off trends show that, within like-for-like risk grades of the Conn's portfolio, charge-off
performance has continuously deteriorated with charge-off rates steadily increasing at a quicker rate than older vintages. This pattern
is ongoing, and we would expect originations in all risk populations to have continued deterioration over time compared to underwriting.
(See supporting charts below.)

 ASC 326-20-55-4 h) The entity's
lending policies and procedures, including changes in lending strategies, underwriting standards, collection, write-off, and recovery
practices, as well as knowledge of the borrower's operations or the borrower's standing in the community or environmental
factors of a borrower and the areas in which the entity's credit is concentrated.

 One of the underlying credit products
that was a revolving loan (store card) which allowed consumers to make purchases in stores. In June 2024, the lines of credit were
frozen which prevented consumers from making future purchases, and loans were put into a paydown posture. This not only reduced the available
credit of the consumers but reduced the utility and incentive to pay for the entire consumer population.

 May 23, 2025

 Page 6

 Consumers had access to in-store payment
options, which simplified payment routines and allowed consumers to easily pay with cash. All stores were closed at the time of portfolio
acquisition. The Installment Loan portfolio received approximately 25% of total payments, and the Revolving Loan portfolio received approximately
60% of payments via in-store channels prior to the Conn's bankruptcy filing in June 2024. The loss of these payment channels materially
reduces consumers' ability to repay as easily and effici

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 May 19, 2025

David Burton
President and CEO
Jefferson Capital, Inc.
600 South Highway 169, Suite 1575
Minneapolis, MN 55426

 Re: Jefferson Capital, Inc.
 Amendment No. 2 to Draft Registration Statement on Form S-1
 Submitted May 5, 2025
 CIK No. 0002046042
Dear David Burton:

 We have reviewed your amended draft registration statement and have the
following
comments.

 Please respond to this letter by providing the requested information and
either
submitting an amended draft registration statement or publicly filing your
registration
statement on EDGAR. If you do not believe a comment applies to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why
in your
response.

 After reviewing the information you provide in response to this letter
and your
amended draft registration statement or filed registration statement, we may
have additional
comments. Unless we note otherwise, any references to prior comments are to
comments in
our February 18, 2025 letter.

Amendment No. 2 to Draft Registration Statement on Form S-1
Risk Factors
Our use of machine learning and AI technologies, page 44

1. We note from your response to comment 1 that you adopted a governance
policy for
 the use of artificial intelligence. Please disclose the substance of
your response in this
 risk factor.
Unaudited Pro Forma Consolidated Financial Information, page 64

2. We note your disclosure on page F-40, and elsewhere, regarding
transactions for the
 issuance of Senior Notes on May 2, 2025. Similarly, we note that you
include
 May 19, 2025
Page 2

 disclosure within footnote 2 on page 60 that it appears you intend to
include those
 notes in your Capitalization table. Please clarify and tell us whether
you have included
 or intend to include pro forma information and adjustments that give
effect to the
 Senior Notes in the May 2, 2025 transaction. Refer to 11-01(a)(8) of
Regulation S-X.
Portfolio Purchasing, page 71

3. We note your disclosure that you occasionally purchase portfolios that
are semi-
 performing and performing. Please define semi-performing
portfolios and expand
 your discussion to explain how semi-performing loans differ from
performing or
 nonperforming loans. Fully explain how you evaluate loan performance
(e.g., credit
 quality assessment) and determine appropriate loan classification as
nonperforming,
 semi-performing, and performing loans. Also, please quantify, here or in
another
 appropriate location, the amount of semi-performing and performing
portfolios for
 each of the periods presented or state that they are immaterial.
Non-GAAP Financial Measures, page 74

4. Please tell us your consideration to present the income tax effects
related to
 your adjustments to calculate and present Adjusted Net Income. Refer to
Question
 102.11 of the Non-GAAP Financial Measures Compliance & Disclosure
 Interpretations.
Results of Operations, page 79

5. We note your disclosure on page 80 regarding total portfolio revenue
trends. Please
 revise to provide a discussion of specific revenue drivers and causes
associated with
 changes in recoveries. Refer to Item 303(b)(2) of Regulation S-K.
Note 1. Organization, Description of Business and Summary of Significant
Accounting
Policies, page F-19

6. We note your disclosures on page F-19 and also page F-22 that you have
purchased
 performing receivable portfolios (i.e., Conn's) that exhibited
more-than-insignificant
 deterioration in credit quality at the time of acquisition and were
accounted for as
 PCD assets under ASC 326. Further, your disclosure on page F-19
indicates that you
 believe you will successfully collect a significant portion where the
consumer will pay
 on a normal schedule. Please provide us with an accounting analysis
explaining the
 factors you considered, including but not limited to those described in
ASC 326-20-
 55-57 through 60, in your determination that these meet the definition
of PCD.
Note 4. Investment in Receivables, Net, page F-24

7. We note that your purchases of $723,253 for the year ended December 31,
2024
 appear to be inconsistent with the amount of negative allowance for
expected
 recoveries of portfolios purchased during the period, totaled $497,189
as reflected in
 footnote 1. Please advise or revise your disclosure to clarify this
discrepancy.
Note 5. Credit Card Receivables, page F-27

8. We note your disclosure on page F-24 that credit card receivables, net
are considered
 short-term in duration. We also note your tabular disclosure of
amortized cost basis
 May 19, 2025
Page 3

 credit card receivables by year of origination (vintage year) indicating
that
 approximately 71% of your credit card receivables as of December 31, 2024
were
 originated in 2020 or prior. Please revise your disclosures to clarify
the distinction or
 potential inconsistency between the two sections. Also, please explain
how you
 determined the year of origination under ASC 326-20-50-6, including how
you
 defined the origination date for credit card receivables (e.g., borrowers
can utilize,
 repay, and reuse available credit over time).
 Please contact Jee Yeon Ahn at 202-551-3673 or Robert Klein at
202-551-3847 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Madeleine Joy Mateo at 202-551-3465 or Todd Schiffman at 202-551-3491
with any
other questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Finance
cc: Erika Weinberg, Esq.
</TEXT>
</DOCUMENT>

February 18, 2025
David Burton
President and CEO
Jefferson Capital, Inc.
600 South Highway 169, Suite 1575
Minneapolis, MN 55426
Re:Jefferson Capital, Inc.
Amendment No. 1 to Draft Registration Statement on Form S-1
Submitted February 5, 2025
CIK No. 0002046042
Dear David Burton:
            We have reviewed your amended draft registration statement and have the following
comments.
            Please respond to this letter by providing the requested information and either
submitting an amended draft registration statement or publicly filing your registration
statement on EDGAR. If you do not believe a comment applies to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
            After reviewing the information you provide in response to this letter and your
amended draft registration statement or filed registration statement, we may have additional
comments. Unless we note otherwise, any references to prior comments are to comments in
our January 8, 2025 letter.
Amendment No. 1 to Draft Registration Statement on Form S-1
Risk Factors
Evolving regulation, particularly in Latin America, page 35
1.In the first paragraph, we note your reference to AI. Please discuss how AI is
deployed and utilized, and include any limitations or risks in relying on AI technology
obtained from third-party service providers. Clarify whether you have introduced
these capabilities outside of Latin America. Discuss whether you have a governance
policy for how you use AI. Clarify if your use of AI in Latin America is your
"PrecisionHandler Solution" application referenced in the penultimate paragraph on
page 112. Finally, also include the requested disclosure on page 112.

February 18, 2025
Page 2
Concentration Risk, page 87
2.We note your disclosure that a substantial percentage of your purchases are
concentrated with a few large sellers, and your disclosure regarding the percentage of
deployments in 2024 and 2023 for which your five largest clients accounted. Please
discuss the material terms of any related agreements with such sellers and file the
agreements as exhibits to the registration statement or tell us why you do not believe
they are required to be filed.
            Please contact Jee Yeon Ahn at 202-551-3673 or Amit Pande at 202-551-3423 if you
have questions regarding comments on the financial statements and related matters. Please
contact Madeleine Joy Mateo at 202-551-3465 or Todd Schiffman at 202-551-3491 with any
other questions.
Sincerely,
Division of Corporation Finance
Office of Finance
cc:Marc Jaffe, Esq.

January 8, 2025
David Burton
President and CEO
Jefferson Capital, Inc.
600 South Highway 169, Suite 1575
Minneapolis, MN 55426
Re:Jefferson Capital, Inc.
Draft Registration Statement on Form S-1
Submitted December 11, 2024
CIK No. 0002046042
Dear David Burton:
            We have reviewed your draft registration statement and have the following comments.
            Please respond to this letter by providing the requested information and either
submitting an amended draft registration statement or publicly filing your registration
statement on EDGAR. If you do not believe a comment applies to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
            After reviewing the information you provide in response to this letter and your
amended draft registration statement or filed registration statement, we may have additional
comments.
Draft Registration Statement on Form S-1
General
Please substantiate, or with respect to beliefs, characterize as such and discuss
your reasonable basis for the belief, the following statements:
•"We believe we are the market leader in the Telecom and Utilities market" (page
9);
"Today, we believe we are the market leader in several asset classes in the United
States, Canada and the United Kingdom including:
othe largest purchaser of nonperforming telecom and utilities receivables in
the United States;
the largest purchaser of both nonperforming and insolvent auto finance o•1.

January 8, 2025
Page 2
receivables in the United States;
othe largest or second largest purchaser of insolvent consumer receivables in
the United States;
othe largest purchaser of both nonperforming and insolvent consumer
receivables in Canada; and
othe largest purchaser of nonperforming telecom and utilities receivables in
the United Kingdom" (page 12);
•"Unlike some of our peers, we pursue nonperforming loan purchase opportunities
across a wide variety of asset classes and in insolvency as well as distressed
receivables and have for a long time been a leader in the United States in those
asset classes" (page 101);
•"We believe we are the largest or second largest purchaser of insolvent consumer
receivables in the United States, and we believe we are the largest purchaser of
insolvent consumer receivables in Canada" (page 106); and
•"In some of our asset classes, we do not believe we have any significant
competitors" (page 110).
2.We note your disclosure on page F-10 that your top five clients accounted for 35.3%
of previously charged-off receivables purchases for the year ended December 31,
2023. Please revise to add a risk factor that addresses material risks to investors
resulting from high concentration in your top clients. In addition, please revise your
MD&A to identify, quantify and analyze any known trends, demands, commitments,
events and uncertainties related to these clients, whether affiliated or unaffiliated, to
the extent they are reasonably likely to have a material effect on your business. Refer
to Item 303 of Regulation S-K.
3.Please supplementally provide us with copies of all written communications, as
defined in Rule 405 under the Securities Act, that you, or anyone authorized to do so
on your behalf, present to potential investors in reliance on Section 5(d) of the
Securities Act, whether or not they retain copies of the communications. Please
contact the staff member associated with the review of this filing to discuss how to
submit the materials, if any, to us for our review.
Cover Page
4.Please state the nature of the underwriting on the cover page and elsewhere as
applicable.
5.Please indicate on the cover and elsewhere as applicable, when you intend to apply to
list your common stock. Indicate whether the offering is contingent upon the listing.
Market and Industry Data, page ii
6.We note your statement that you have not independently verified any of the data from
third-party sources and that "there can be no assurance as to the accuracy or
completeness of included information." Since you are responsible for the accuracy and
completeness of information in the prospectus, please remove any statements
implying that you are not responsible.

January 8, 2025
Page 3
Prospectus Summary
Competitive advantages from variable cost business model with proprietary collection
capabilities, page 13
7.Please expand your discussion to explain the unique legal and digital capabilities you
reference in this section. Additionally, we note your reference to your proprietary
technologies and business processes. Please revise your disclosure where appropriate
to describe such technologies and processes, including PrecisionHandler Solution,
VeriCredit, Recovery Solution, RefundTrack, CustomerCare Solution,
OptimizedOffer Solution and JFRAME360, and explain how these technologies and
processes help you sustain your efficiency advantage.
8.For the technologies and business processes you reference, describe the extent to
which you are dependent on open source code or platforms controlled by other
entities.
Our Growth Strategy, page 14
9.To the extent that your growth strategy will require additional funds, including
possible sales of securities, please discuss here or elsewhere as applicable, the
potential dilutive effect of future offerings. We note in particular that the company
will not receive any funds from this offering.
Enter the high street bank market in the United Kingdom, page 16
10.Please revise your disclosure to explain what is meant by your reference to "high
street" banks.
Our Sponsor, page 23
11.Please revise your disclosure to clarify the current role and function of J.C. Flowers as
the sponsor of your company. Please also provide a description of the transactions in
which the selling stockholders obtained the securities being sold pursuant to this
registration statement.
Summary Consolidated Financial and Operating Information, page 27
12.Please revise the header of the tabular financial and operating information presented
to mark the summary data for the years ended December 31, 2024 and 2023 as
Audited.
Risk Factors, page 31
13.We note your disclosure on page 17 and page 102 that your purchasing and client
relationships are characterized by very low concentration. Please clarify what you
mean by this statement and if this may be considered a material risk, please add risk
factor disclosure.
Risks Related to our Business, page 31
We note that in 2022 the CFPB entered into a consent order with a large national bank
relating to garnishment-related practices, including out-of-state garnishments. To the
extent that you pursue garnishments against borrowers with accounts held outside of 14.

January 8, 2025
Page 4
the state where they reside, please revise this section to add a risk factor discussing the
possible impact of the CFPB's actions on your ability to recover funds. In the
alternative, tell us about your compliance procedures if you do not believe this is a
material risk.
15.Consider adding a risk factor discussing any risks from the Conn's portfolio purchase
such as assuming 200 FTE Conn's servicing employees, adding a new operating site,
and any impairment risk if your assumptions regarding collections are not fully met.
Our international operations expose us to risks, which could harm our business, page 34
16.This risk factor addresses multiple risks related to your international operations.
Please consider breaking out the risks and discussing the most significant of these
risks in separate, more detailed risk factors.
A significant portion of our total outstanding shares are restricted from immediate resale but
may be sold, page 43
17.Please quantify the approximate amount and percentage of shares subject to the lock-
up agreements. In addition, provide this disclosure on page 141.
Use of Proceeds, page 52
18.In light of the fact that the company will not receive any proceeds, state here and in
the Prospectus Summary, why you are doing an initial public offering now.
Supplemental Performance Data as of December 31, 2024
Previously Charged-Off Receivables Portfolio Performance, page 71
19.We note your disclosure on page 62 that your revenue is primarily derived from
revenue from previously charged-off receivables. In order to provide investors with a
better understanding of the performance of your charged-off receivables portfolios,
please consider including a tabular presentation summarizing collections from
purchased receivables, revenues from receivable portfolios, end of period receivable
balance and other related supplemental data, by year of purchase.
Critical Accounting Estimates, page 81
20.We note that your discussion of your critical accounting estimates appears to duplicate
information from significant accounting policies disclosed in the financial statement
footnotes. Please revise to include an enhanced discussion for each critical accounting
estimate including for instance, information necessary to understand the estimation
uncertainty and, to the extent the information is material and reasonably available,
how much each estimate and/or assumption has changed over a relevant period, and
the sensitivity of the reported amounts to the material methods, assumptions and
estimates underlying its calculation. Refer to Item 303(b)(3) of Regulation S-K.
Exclusive Forum, page 139
We note your disclosure that the federal district courts of the United States of America
will be the exclusive forum for the resolution of any complaint asserting a cause or
causes of action against you or any defendant arising under the Securities Act. Please 21.

January 8, 2025
Page 5
revise to state that there is uncertainty as to whether a court would enforce such
provision. Please also state that investors cannot waive compliance with the federal
securities laws and the rules and regulations thereunder. In that regard, we note that
Section 22 of the Securities Act creates concurrent jurisdiction for federal and state
courts over all suits brought to enforce any duty or liability created by the Securities
Act or the rules and regulations thereunder. We also note your disclosure about waiver
in the final sentence.
Description of Certain Indebtedness
Revolving Credit Facility, page 142
22.Please disclose your current standing under the Revolving Credit Facility and whether
you are in compliance with the restrictive covenants of this credit facility.
Additionally, we note that the Revolving Credit Facility is secured by substantially all
of the assets of four of your operating subsidiaries, CL Holdings, LLC, Jefferson
Capital Systems, LLC, JC International Acquisition, LLC and CFG Canada Funding,
LLC. Please consider adding risk factor disclosure discussing the risks to your
business related to an event of default under the Revolving Credit Facility.
Note 1. Organization, Description of Business and Summary of Significant Accounting
Policies
Investments in Previously Charged-off Receivables, page F-11
23.We note your disclosure on page F-11 that your revenue from receivable portfolios
includes all revenue from zero basis portfolio collections. Please tell us what zero
basis portfolios represent and the amount of revenue recognized from them for each of
the periods presented.
Servicing Expenses, page F-14
24.We note on page 64 that legal fees associated with the collection of a debt are
included in servicing expenses. Please tell us the amount of legal fees associated with
debt collection recognized in each of the periods presented and revise to separately
present any material components of your servicing expenses and discuss any observed
changes in trends.
Note 5. Credit Card Receivables, page F-18
25.Please clarify the components of your credit card receivables (e.g., revolving loans,
term loans) and provide a discussion of the risk characteristics relevant to each of your
loan portfolio segments. In addition, please revise to disclose the amount of line-of-
credit arrangements that are converted to term loans in each reporting period. Refer to
ASC 326-20-50-6A.

January 8, 2025
Page 6
            Please contact Jee Yeon Ahn at 202-551-3673 or Amit Pande at 202-551-3423 if you
have questions regarding comments on the financial statements and related matters. Please
contact Madeleine Joy Mateo at 202-551-3465 or Todd Schiffman at 202-551-3491 with any
other questions.
Sincerely,
Division of Corporation Finance
Office of Finance
cc:Marc Jaffe, Esq.