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July 26, 2019

VIA EDGAR

Securities and Exchange Commission
100 F Street NE
Washington, D.C. 20549

Re: Pomona Investment Fund

(File Nos. 333-224664 and 811-22990)

Ladies and Gentlemen:

On behalf of Pomona Investment Fund (the “Registrant”), electronically transmitted for filing is Post-Effective Amendment No. 2 to the Registrant’s registration statement on Form N-2 (“Registration Statement”) under the Securities Act of 1933, as amended and Amendment No. 15 to the Registration Statement under the Investment Company Act of 1940, as amended. This filing is being made for the purpose of (i) incorporating comments received from the Securities and Exchange Commission staff in connection with Post-Effective Amendment No. 1 to the Registration Statement; and (ii) updating certain other information.

No fee is required in connection with this filing. Please direct any questions concerning the filing to the undersigned at 202-261-3386.

Very truly yours,

/s/ William J. Bielefeld__________

William J. Bielefeld