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[LETTERHEAD
OF SUTHERLAND ASBILL & BRENNAN LLP]
January
6, 2011
VIA EDGAR
U.S.
Securities and Exchange Commission
100 F
Street, N.E.
Washington,
D.C. 20549
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|
Re:
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NeXt BDC Capital Corp.
– Form N-2 Registration
Statement
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Dear
Sir/Madam:
On behalf
of NeXt BDC Capital Corp. (the “Company”), we are transmitting herewith for
filing under the Securities Act of 1933, as amended, the Company’s registration
statement on Form N-2 (the “Registration Statement ”) relating to its proposed
initial public offering. The applicable filing fee for the submission of the
Registration Statement in the amount of $5,805 was deducted from the Company’s
EDGAR account.
If you
have any questions or comments regarding the Registration Statement, please do
not hesitate to contact the undersigned at (202) 383-0176 or John J. Mahon at
(202) 383-0515.
Sincerely,
/s/ Steven B. Boehm
Steven B. Boehm