[Letterhead of Sutherland Asbill & Brennan LLP]
June 28, 2007
Vincent J. Di Stefano, Esq.
Senior Counsel
Division of Investment Management
U.S. Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Re: | Technology Investment Capital Corp. |
Registration Statement on Form N-2 filed on April 16, 2007
File No. 333-142154
Dear Mr. Di Stefano:
On behalf of Technology Investment Capital Corp. (the Company), set forth below is the Companys response to the oral comment provided by the staff of the Division of Investment Management (the Staff) of the Securities and Exchange Commission (the SEC) to the Company on June 27, 2007 regarding the Companys Registration Statement on Form N-2 (File No. 333-142154) (the Registration Statement), and the prospectus included therein (the Prospectus). The Staffs comment is set forth below and is followed by the Companys response.
1. | We note your response to our prior oral comment regarding the calculation of the capital gains portion of your investment advisers incentive fee. Please revise your disclosure to provide greater detail regarding the method of calculation. |
The Company has revised the disclosure set forth in the section of the Prospectus entitled Portfolio ManagementInvestment Advisory Agreement in response to the Staffs comment.
Mr. Vincent J. Di Stefano
June 28, 2007
Page 2 of 2
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If you have any questions or additional comments concerning the foregoing, please contact Steve Boehm at (202) 383-0176 or Cynthia M. Krus at (202) 383-0218.
Sincerely, |
/s/ Steven B. Boehm |
Steven B. Boehm |
/s/ Cynthia M. Krus |
Cynthia M. Krus |