November 19, 2018
VIA E-MAIL

John T. Fitzgerald, Esq.
Lord Abbett & Co. LLC
90 Hudson Street
Jersey City, New Jersey 07302

           RE:      Lord Abbett Credit Opportunities Fund
                    Initial Registration Statement on Form N-2
                    File Nos. 333-227612 and 811-23383

Dear Mr. Fitzgerald,

        On September 28, 2018, you filed a registration statement on Form N-2
under the
Securities Act of 1933 and the Investment Company Act of 1940 ("1940 Act") on
behalf of the
Lord Abbett Credit Opportunities Fund (the "Fund").

We have reviewed the filing and have the following comments. 1

General

       1. We note that portions of the registration statement are missing
information or contain
          bracketed disclosure. We may have additional comments on such
portions when you
          complete them in a pre-effective amendment, on disclosures made in
response to this
          letter, on information supplied supplementally, or on exhibits added
in any pre-effective
          amendment.

       2. Please note that comments we give on disclosure in one section apply
to other sections of
          the filing that contain the same or similar disclosure.

       3. In "The Offering" section on page 1, there is a reference to the Fund
seeking multi-class
          share class relief. Please advise us if you have begun the process to
seek this relief or
          have determined when you will do so.

       4. Please confirm whether a party other than the Fund's sponsor or one
of its affiliates is
          providing the Fund's initial (seed) capital. If yes, please
supplementally identify the
          party providing the seed capital and describe its relationship with
the Fund.


1
    Capitalized terms have the same meaning as in the registration statement
unless otherwise indicated.
 Page 2 of 6




Front Cover Page

   5. Please disclose the amount of securities to be offered. Item 1.c of Form
N-2.

   6. Under "Investment Strategy," please disclose that high yield debt
securities are also
      known as "junk bonds" the first time high yield is mentioned in the first
sentence of the
      first paragraph.

   7. Under "Investment Strategy," with respect to the last sentence of the
first paragraph,
      please confirm supplementally that derivatives will be valued on a
mark-to-market basis
      for purposes of meeting the 80% test.

   8. Under "Interval Fund/Repurchase Offers," please disclose the intervals
between
      deadlines for repurchase requests, pricing, and repayment and, if
applicable, the timing of
      the initial repurchase offer. In doing so, please also include a
cross-reference to the
      prospectus sections that discuss repurchase policies and their attendant
risks. See Guide
      10 to Form N-2.

   9. The "Investment Risks" section refers to "emerging markets." Please add
corresponding
      disclosure in both the principal investment strategies section of the
Summary beginning
      on page 2 and to the fuller discussion beginning on page 33. Also
disclose how the Fund
      defines an emerging market security.

   10. The "Investment Risks" section refers to "leverage." Please provide
specific cross-
       references to the discussion of this risk. Item 1.1.j of Form N-2.

   11. At the end of the fourth to last paragraph before the date of the
prospectus, please provide
       a more specific website address.

Prospectus Summary

   12. The Fund's current disclosure regarding the Fund and its objectives,
investments,
       policies, and risks in response to Items 8.2 and 8.3 of Form N-2 is
virtually identical to
       the information in the Prospectus Summary. Please revise so that the
Prospectus
       Summary is in fact a summary of the more detailed disclosure contained
elsewhere in the
       prospectus.

   13. Under "Portfolio Composition   High-Yield Debt Securities" on page 5,
please reiterate
       that high-yield debt securities are also known as "junk bonds."

   14. Under "Portfolio Composition   Equity Securities" on page 11, you note
that the Fund
       may invest up to 20% of its total assets in equity securities including
privately offered
       trusts. Please tell us how much the Fund will invest in private equity
funds that rely on
 Page 3 of 6


       section 3(c)(1) or 3(c)(7) of the 1940 Act. We may have additional
comments after
       reviewing your response.

Summary of Fund Expenses (page 32)

   15. Under "Shareholder Transaction Expenses," please delete the phrase "on
Shares
       Repurchased Within One Year of Purchase" from the third line item and
provide the
       variation disclosure in a footnote.

   16. The parenthetical for Annual Fund Operating Expenses notes that they are
expressed as
       "expenses that you pay each year as a percentage of the value of your
investments."
       Please revise to express all annual expenses as a percentage of net
assets attributable to
       common shares.

   17. Please provide footnote 1 to the Example as narrative following the
example rather than
       in its current footnote format.

Prospectus

Principal Investment Risks of the Fund (page 43)

   18. Please confirm all disclosure regarding "Repurchase Offers Risk" on page
44, as outlined
       in Guide 10 to Form N-2, has been provided. In particular, disclose the
effect that
       repurchases may have on the Fund's ability to qualify as a regulated
investment company
       and potential tax consequences to investors and the Fund from
repurchases and related
       portfolio security sales.

       In the first sentence of the disclosure, please revise "above" to
specific cross-reference to
       the discussion of Periodic Repurchase Offers" beginning on page 68.

   19. Please add disclosure to "Foreign and Emerging Market Company Risk" on
page 50
       regarding: 1) the difficulty in obtaining or enforcing a court judgment
abroad; 2)
       difficulties in effecting repatriation of capital invested abroad; and
otherwise confirm all
       relevant material risks have been disclosed per Guide 9 to Form N-2.

   20. Please add disclosure to "Leverage Risk" on page 58 indicating: 1) that
decline in net
       asset value could affect the ability of the Fund to make common stock
dividend
       payments; 2) that a failure to pay dividends or make distributions could
result in the Fund
       ceasing to qualify as a regulated investment company under the Internal
Revenue Code;
       and 3) that if the asset coverage for preferred stock or debt securities
declines to less than
       required amounts two hundred percent or three hundred percent,
respectively (as a result
       of market fluctuations or otherwise), the Fund may be required to sell a
portion of its
       investments when it may be disadvantageous to do so. See Guide 6 to Form
N-2.

   21. Please add the following disclosure to "Zero Coupon, Deferred Interest,
Pay-in-Kind and
       Capital Appreciation Bonds Risk" on page 59: 1) the interest rates on
PIK loans are
 Page 4 of 6


       higher to reflect the time-value of money on deferred interest payments
and the higher
       credit risk of borrowers who may need to defer interest payments; 2) PIK
instruments
       may have unreliable valuations because the accruals require judgments
about ultimate
       collectability of the deferred payments and the value of the associated
collateral; 3) use of
       PIK securities may provide certain benefits to the fund's adviser
including increasing
       management fees; and 4) the required recognition of PIK interest for
U.S. federal income
       tax purposes may have a negative impact on liquidity, because it
represents a non-cash
       component of the Fund's taxable income that must, nevertheless, be
distributed in cash to
       investors to avoid it being subject to corporate level taxation.

   22. The risk disclosure for "Anti-Takeover Provisions" on page 62 does not
currently provide
       a substantive summary of the relevant provisions or risks. Please
provide additional
       information in the Prospectus Summary under "Anti-Takeover Provisions,"
as well as
       more complete information in the fuller discussion of risks. Item 19.1.f
of Form N-2. See
       also Guide 3 to Form N-2.

Management of the Fund (page 62)
   23. In the last sentence under "Management Fee" on page 62, please disclose
the period to be
       covered by the applicable report. Item 9.1.b(4) of Form N-2.

   24. It appears that the Fund will invest a substantial amount of assets in
foreign securities,
       therefore, under "Portfolio Managers" on page 63 please provide a basis
to assess the
       expertise and experience of the Adviser and/or portfolio managers with
respect to foreign
       investments. See Guide 9 to Form N-2.

   25. Under "Additional Information" on page 63, please delete "that cannot be
waived" at the
       end of the first sentence of the second paragraph or disclose those
rights that cannot be
       waived.

Plan of Distribution (page 64)

   26. In the first sentence of the second paragraph, please briefly describe
the "various
       conditions" required for a best efforts distribution. See Instructions
to Item 5.1.d of Form
       N-2.

   27. For "Servicing Arrangements" please disclose all information required by
Item 5.10 of
       Form N-2 for other entities like broker-dealers and banks through which
the Fund shares
       might be available.

Purchasing Shares (page 65)

   28. Please disclose the date by which an investor must pay for securities.
Item 5.6 of Form N-
       2.
 Page 5 of 6


Acceptance and Timing of Purchase Orders (page 67)

   29. With respect to the fifth sentence of the first paragraph ("If the NYSE
is closed due to
       weather ...."), please disclose how NAV would then be calculated.

Periodic Repurchase Offers (page 68)

   30. In the first sentence of the second paragraph, please disclose the
specific voting
       requirements for shareholder approval of a change to this fundamental
policy.

Dividend Reinvestment Plan (page 72)

   31. Please disclose the method of determining the number of shares that will
be distributed
       instead of a cash dividend. Item 10.1.e(4) of Form N-2.

Custodian and Transfer Agents (page 76)

   32. If the transfer agent is a different entity than the custodian, then
please provide the
       principal business address for the transfer agent as well. Item 10.1.e
of Form N-2.

Statement of Additional Information

   33. Under "Temporary Defensive Investments" on page 2-39, the securities
that are listed to
       be used in temporary defensive positions differ than those listed on
page 43 of the
       prospectus, i.e., high-quality debt instruments maturing in one year or
less. Please
       reconcile.

   34. Under "Investment Restrictions" on page 3-1, please disclose any
fundamental policy of
       the Fund with respect to short sales, purchases on margin, and the
writing of put and call
       options. Item 17.2.b of Form N-2. Please also provide the descriptions
of the current 1940
       Act limitations as referenced in the first sentence of the first
paragraph on page 3-2.

   35. For the table of Trustees and Officers beginning on page 5-1, please
provide a column for
       the number of portfolios in the fund complex overseen by the trustee.
Item 18.1 of Form
       N-2.

   36. In the table under "Committees" on page 5-5, the column for "Nominating
and
       Governance Committee" refers the reader to "Shareholder Communications"
on page 5-
       6. In the latter section, please disclose the procedures to submit
nominations.

   37. Please move the disclosure under the caption "Committee Meetings" at the
bottom of
       page 5-7 to the "Committees" section on page 5-5.

   38. In addition to "Other Accounts Managed" and "Holdings of Portfolio
Managers" on page
       5-8, please also provide information regarding conflicts and
compensation per Items
       21.1.d and 21.2 of Form N-2, respectively.
 Page 6 of 6



Part C

   39. Please include a seed capital balance sheet as required by Section
14(a)(1) of the 1940
       Act.

   40. Please state that the Form ADV identified is incorporated by reference
into Part C.


                                            ********
        Responses to this letter should be made in a letter to me filed on
EDGAR and in the form
of a pre-effective amendment filed pursuant to Rule 472 under the Securities
Act. Where no
change will be made in the filing in response to a comment, please indicate
this fact in the letter
to us and briefly state the basis for your position.
        You should review and comply with all applicable requirements of the
federal securities
laws in connection with the preparation and distribution of a preliminary
prospectus.
        Although we have completed our initial review of the registration
statement, the filing
will be reviewed further after we receive your response. Therefore, we reserve
the right to
comment further on the registration statement and any amendments. After we have
resolved all
issues, the Fund and its underwriter must request acceleration of the effective
date of the
registration statement.
         In closing, we remind you that the Fund is responsible for the
accuracy and adequacy of
its disclosure in the registration statement, notwithstanding any review,
comments, action, or
absence of action by the staff.
        Should you have any questions prior to filing a pre-effective
amendment, please feel free
to contact me at (202) 551-6767 or ohm@sec.gov.

                                                             Sincerely,

                                                             /s/ Sonny Oh

                                                             Sonny Oh
                                                             Senior Counsel


cc: William Kotapish
    Sumeera Younis