January 29, 2025

VIA E-mail

Matthew J. Carter, Esq.
Dechert LLP
1900 K Street, NW
Washington, DC 20006

         Re: CCS IX Portfolio Holdings, LLC
             File No. 000-56718

Dear Mr. Carter:
         On December 31, 2024, you filed a registration statement on Form 10 on
behalf of CCS
IX Portfolio Holdings, LLC (the    Company   ). We have reviewed the
registration statement and
have provided our comments below. Where a comment is made in one location, it
is applicable
to all similar disclosure appearing elsewhere in the registration statement.
All capitalized terms
not otherwise defined herein have the meaning given to them in the registration
statement.
       Please respond to this letter within ten (10) business days by either
amending the filing,
providing the requested information, or advising us when you will provide the
requested
information. We may have additional comments after reviewing your responses to
the following
comments, or any amendment to the filing.
         We note that the Company is voluntarily registering shares of its
common stock under
Section 12(g) of the Securities Exchange Act of 1934 (   Exchange Act   ).
Please note that a filing
on Form 10 goes effective automatically by lapse of time 60 days after the
original filing date,
pursuant to Exchange Act Section 12(g)(1). If our comments are not
satisfactorily addressed
within this 60-day time period, you should consider withdrawing the Company   s
Form 10 prior
to its effectiveness, and re-filing a revised Form 10 that includes changes
responsive to our
comments. If the Company chooses not to withdraw its Form 10 registration
statement, it will be
subject to the reporting requirements of Exchange Act Section 13(a).
Additionally, we will
continue to review the filing until all of our comments have been
satisfactorily addressed.
 Mr. Matthew J. Carter, Esq.
January 29, 2025


REGISTRATION STATEMENT
Explanatory Note (page 1)
    1. Please include the following in the explanatory note, as applicable:
           a. The Company   s common stock is not currently listed on an
exchange, and it is
              uncertain whether a secondary market will develop;
           b. Repurchases of common stock by the Company, if any, are expected
to be very
              limited;
           c. An investment in the Company may not be suitable for investors
who may need
              the money they invest in a specified time frame;
           d. Investment in the Company is suitable only for sophisticated
investors and
              requires the financial ability and willingness to accept the high
risks and lack of
              liquidity inherent in an investment in the Company;
           e. The Company intends to invest primarily in privately-held
companies for which
              very little public information exists. Such companies are also
generally more
              vulnerable to economic downturns and may experience substantial
variations in
              operating results; and
           f. The privately-held companies and below-investment-grade
securities in which the
              Company will invest will be difficult to value and are illiquid.
   2.    Please confirm supplementally, if accurate, that the number    IX
as used in the
         Company name does not have any particular meaning in connection with
the
         Company   s strategy.
   3.    Given the lengthy discussion of risk factors that begins on page 25,
please include at
         the beginning of the filing a series of concise, bulleted or numbered
statements that is
         no more than two pages summarizing the principal risk factors.
Item 1. Business (page 3)
   4.    Page 3 indicates that the Company intends to elect to be regulated as
a BDC. Please
         disclose when election to be regulated as a BDC will be filed.
   5.    The first sentence in the second paragraph on page 3 states that that
the investment
         objective is to provide unitholders with    substantial current income
and long-term
         capital appreciation       Please disclose how the Company is defining
   substantial.
   6.    The last sentence in the second paragraph on page 3 states that the
Company may also
         invest in    other debt or equity securities.    Please clarify in
disclosure the nature of any
         such other debt or equity securities.
   7.    The third paragraph on page 3 states that the Company   s investment
objective is
         accomplished through, among other things,    originating investments
in what we believe
         to be middle-market companies with strong business fundamentals
Please briefly
         explain supplementally the use of the language    what we believe to
be    in this


          Page 2 of 7
 Mr. Matthew J. Carter, Esq.
January 29, 2025


         sentence, and please clarify in disclosure how the Company is
defining/considering
            strong business fundamentals.
    8. The sixth paragraph on page 3 indicates that the Company may form
wholly-owned
       subsidiaries. To the extent that the Company will have primary control
over any entities
       that primarily engage in investment activities in securities or other
assets, please respond
       to the following comments:
           a. Disclose that such subsidiaries include entities that engage in
investment activities
              in securities or other assets that are primarily controlled by
the Company;
           b. Disclose that the Company complies with the provisions of the
Investment
              Company Act governing investment policies (Section 8) on an
aggregate basis
              with the subsidiary;
           c. Disclose that the Company complies with the provisions of the
Investment
              Company Act governing capital structure and leverage (Section 18,
as modified
              by Section 61) on an aggregate basis with the subsidiary so that
the Company
              treats the subsidiary   s debt as its own for purposes of Section
18;
           d. Disclose that any investment adviser to the subsidiary complies
with provisions of
              the Investment Company Act relating to investment advisory
contracts (Section
              15 as it applies through Section 59) as if it were an investment
adviser to the
              Company under Section 2(a)(20) of the Investment Company Act;
           e. Disclose that each subsidiary complies with provisions relating
to affiliated
              transactions and custody (Section 17 as modified by Section 57).
Identify the
              custodian of the subsidiary, if any;
           f. Disclose any of the subsidiary   s principal investment
strategies or principal risks
              that constitute principal investment strategies or risks of the
Company. The
              principal investment strategies and principal risk disclosures of
a fund that invests
              in a subsidiary should reflect aggregate operations of the fund
and the subsidiary;
           g. Explain in correspondence whether the financial statements of the
subsidiary will
              be consolidated with those of the Company. If not, please explain
why not;
           h. Confirm in correspondence that the subsidiary and its board of
directors will agree
              to inspection by the staff of the subsidiary   s books and
records, which will be
              maintained in accordance with Section 31 of the Investment
Company Act and the
              rules thereunder as modified by Section 64 of the 1940 Act;
           i. Confirm in correspondence that the wholly-owned subsidiary   s
management fee
              (including any performance fee), if any, will be included in
Management Fees,
              and the wholly-owned subsidiary   s expenses will be included in
  Other
              Expenses    in the Company   s fee table, as appropriate; and
           j. Please disclose that the Company does not/does not currently
intend to create or
              acquire primary control of any entity which primarily engages in
investment
              activities in securities or other assets, other than entities
wholly-owned by the
              Company.



         Page 3 of 7
 Mr. Matthew J. Carter, Esq.
January 29, 2025


    9. Please reconcile the language in the "Base Management Fee" section on
page 8 versus
       the language in the "Investment Advisory and Management Agreement" with
respect to
       how the fee is calculated and payment frequency.
    10. Please confirm whether the Company will utilize leverage during the
first year of
        investment operations.
Investment Strategy (pages 4-7)
    11. The first sentence under the    Investment Strategy    subheading on
page 4 indicates that
        the Company   s strategy will seek to generate    substantial current
income and
        meaningful long-term capital gains.    Please disclose how the Company
defines
           substantial    and    meaningful    in this context.
    12. The second sentence of the second paragraph under the    Investment
Strategy
        subheading on page 4 indicates that the Adviser   s strategy seeks to,
among other things,
           provide for enhanced controls       Please clarify in disclosure
what the Company means
        by    enhanced controls.
    13. Does the Company currently hold any investments, or intend to hold any
investments,
        prior to effectiveness of the registration statement? Has the Company
entered into, or
        does the Company intend to enter into, any warehousing transaction for
purposes of
        establishing the initial investment portfolio of the Company?
Private Offering of Common Units (page 7)
    14. Will the terms of the Subscription Agreements referenced on page 7
materially differ
        depending on the investor? We may have further comments. Please also
see Comment
        33 below.
Investment Advisory Agreement (page 8)
    15. The disclosure on page 8 under "Investment Advisory Agreement" states
that the
        Company "intends" to enter into an advisory agreement with the Adviser.
Please
        supplementally explain when the Company intends to enter into such an
agreement. If
        the Company does not enter into such an agreement prior to offering
shares, please
        supplementally explain how the Company will be managed.
    16. Please consider including a fee table that complies with the
requirements of Form N-2.
    17. Please confirm in correspondence whether the Company has any incentive
fee
        arrangements. If there is an incentive arrangement, please include
details of the
        incentive compensation and include an example of how the calculations
work.
Item 1A. Risk Factors (pages 25-52)
    18. Please ensure that each strategy disclosed in the Company   s principal
investment
        strategy is addressed in the principal risk section, and vice versa.
Specifically, please be
        sure the following investment types, which appear to be addressed in
the principal risk
        section, are also discussed in the Company   s principal strategy
section: floating rate
        debt; illiquid loans/securities; unrated/high-yield/junk debt; CLOs;
covenant-lite loans;


          Page 4 of 7
 Mr. Matthew J. Carter, Esq.
January 29, 2025


        first-lien senior secured loans/unitranche loans; syndicated loans; and
debt of leveraged
        companies.
    19. Disclose the cost of    34 Act reporting as an additional risk, or
direct us to such
        disclosure.
    20. Please disclose how long it is expected to take to fully invest net
proceeds in accordance
        with the Company   s investment objectives and policies, the reasons
for any anticipated
        lengthy delay in investing the net proceeds, and the consequences of
any delay.
    21. Disclosure on page 42 references the use of credit derivatives. Please
discuss the use of
        credit or other derivatives in the principal strategy section,
including the extent to which
        any such derivatives may be used.
    22. Disclosure on page 44 indicates that the Company expects substantially
all of its
        investments will involve loans and private securities. Please
supplementally explain
        whether the Company will invest more than 15% of its assets in funds
relying on the
        exclusions under Sections 3(c)(1) and/or 3(c)(7) of the 1940 Act. We
may have
        additional comments.
Item 4. Security Ownership of Certain Beneficial Owners and Management (page
56)
    23. Please revise the table on page 56 to include a column listing the
class of security.
Item 5. Directors and Executive Officers (page 56)
    24. Disclosure on page 3 states that the Board consists of five directors,
three of whom are
        independent. Please reconcile this with disclosure on page 56, which
indicates that the
        Board consists of six members, five of whom are not    interested
persons.
Item 7. Certain Relationships and Related Transactions, and Director
Independence (pages
61-62)
    25. Disclosure on page 62 references an Expense Support Agreement. Please
consider
        disclosing an expense example that conforms to the requirements of
Instruction 11 to
        Item 3.1 of Form N-2. We believe that such disclosure would be helpful
to investors.
    26. Please also provide examples demonstrating the operation of an
incentive fee, and a
        graphical representation of the income-related portion of any incentive
fee.

Item 15. Financial Statements and Exhibits (pages 69-70)
    27. Please provide a copy of the Company's bylaws.
    28. Please file finalized documents and agreements, rather than any    form
of    agreements.
    29. Please furnish all financial statements and supplementary financial
information required
        by Regulation S-X at least 15 days prior to the Form 10's effectiveness
to allow us
        enough time to review. Audited financial statements, supplemented by
interim period
        financial statements, if required, should be dated within 135 days.





             Page 5 of 7
 Mr. Matthew J. Carter, Esq.
January 29, 2025


    30. In an amendment, please include an estimate of organizational and
offering costs
        incurred. In addition, please consider disclosing the accounting
treatment for these costs
        that aligns with the disclosure in the notes to the financial
statements.
    31. In connection with the First Amended and Restated Limited Liability
Company
        Agreement included as Exhibit 3.3 (   LLC Agreement   ), please revise
the provision
        under Section 12.6(d) to state that the exclusive Delaware forum
provision does not
        apply to claims arising under the federal securities laws. Please also
disclose in an
        appropriate location in the prospectus the provision and corresponding
risks of such a
        provision even as to non-federal securities law claims (e.g., that
shareholders may have
        to bring suit in an inconvenient and less favorable forum) and that the
provision does not
        apply to claims arising under the federal securities laws.
    32. In connection with Section 12.6(g) of the LLC Agreement, please confirm
the following
        supplementally, and also make any related revisions to the disclosure,
or otherwise
        explain how such terms comply with federal securities laws (e.g.,
Adviser's fiduciary
        duty, Reg F-D):
           a. The Adviser will not provide investors or others with information
that would
              allow those investors to benefit at the Company's expense;
           b. The Company will not make selective disclosure of material
information,
              including portfolio holdings of the Company.
    33. In connection with Section 12.6(j) of the LLC Agreement, and
specifically the language
        referencing the Company   s ability to enter into side letters with
individual Members
        (   Other Agreement   ), please explain the following supplementally:
           a. How having subscription agreements and/or side letters with
different terms
              would comply with Sections 18/61 under the 1940 Act (e.g., could
it result in an
              investor having priority over any other investor as to
distribution of assets or
              payment of dividends?);
           b. Whether different terms in any subscription agreement and/or side
letter could
              have a material, negative effect on other Company investors;
           c. Whether the terms of different subscription agreements and/or
side letters will be
              disclosed to all Company investors, and how they will be
disclosed including the
              timing of such disclosure;
           d. Whether the terms of these subscription agreements and/or side
letters include
              preferential redemption or withdrawal rights, or about portfolio
holdings or
              exposures; and
           e. Whether the terms of these subscription agreements and/or side
letters have a
              direct or indirect effect on the management fee attributable to
the applicable
              shareholders with whom such agreements are made.
General Comments
    34. Response to this letter should be in the form of a pre-effective
amendment filed under the
        Exchange Act. The amendment filing should be accompanied by a
supplemental letter
        that includes your responses to each of these comments. Where no change
will be made


        Page 6 of 7
 Mr. Matthew J. Carter, Esq.
January 29, 2025


         in the filing in response to a comment, please indicate this fact in
your supplemental letter
         and briefly state the basis for your position.
      35. Please advise us if you have submitted, or expect to submit, any
exemptive application or
          no-action request in connection with the registration statement.
      36. We urge all persons who are responsible for the accuracy and adequacy
of the disclosure
          in the filings reviewed by the staff to be certain that they have
provided all information
          investors require for an informed decision. Since the Company and its
management are
          in possession of all facts relating to Company disclosure, they are
responsible for the
          accuracy and adequacy of the disclosures they have made.


                                       *   *    *   *     *   *

         We remind you that the Company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence of
action by the staff. Should you have any questions regarding this letter,
please contact me at
(213) 320-8886 or brodskya@sec.gov.

                                                        Sincerely,

                                                        /s/ Aaron Brodsky

                                                        Aaron Brodsky
                                                        Attorney-Adviser

cc:     Thankam Varghese, Branch Chief
        Michael Spratt, Assistant Director





            Page 7 of 7