CORRESP 1 filename1.htm corresp.htm

Graham Capital Management, L.P.
40 Highland Avenue
Rowayton, Connecticut 06853


June 22, 2010

Mail Stop 3010

VIA EDGAR AND FEDEX

Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, D.C. 20549
 
Attn:
Sonia Barros
 
Special Counsel

Re:
Graham Alternative Investment Fund I LLC
 
Form 10
 
Filed April 30, 2010
 
File No. 000-53965

Ladies and Gentlemen:

On behalf of Graham Alternative Investment Fund I LLC (the “Fund”), I am writing this letter in my capacity as an officer of Graham Capital Management, L.P., the manager of the Fund (the “Manager”).  This letter responds to the Securities and Exchange Commission (the “Commission”) Staff’s comment letter dated May 28, 2010, (the “Letter”) to the Fund’s Registration Statement on Form 10 that was filed with the Commission on April 30, 2010.  For your convenience, the Staff’s comments are indicated in italics, followed by the response of the Manager.

 
1.
In connection with responding to our comments, please provide, in writing, a statement from the company acknowledging that:

the company is responsible for the adequacy and accuracy of the disclosure in the filing;

staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing; and

the company may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

The Fund acknowledges that it is responsible for the adequacy and accuracy of the disclosures in the filing.

The Fund is aware that Staff comments or changes to disclosures in response to Staff comments do not foreclose the Commission from taking any action with respect to the filing.

The Fund may not assert Staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities law of the United States.

Please feel free to call the undersigned at (203) 899-3491 with any questions.

 
Very truly yours,
   
 
/s/ Paul Sedlack
   
 
Paul Sedlack
 
Chief Executive Officer


cc:  Christopher Wells