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                                                              May 19, 2025

David Burton
President and CEO
Jefferson Capital, Inc.
600 South Highway 169, Suite 1575
Minneapolis, MN 55426

       Re: Jefferson Capital, Inc.
           Amendment No. 2 to Draft Registration Statement on Form S-1
           Submitted May 5, 2025
           CIK No. 0002046042
Dear David Burton:

     We have reviewed your amended draft registration statement and have the
following
comments.

       Please respond to this letter by providing the requested information and
either
submitting an amended draft registration statement or publicly filing your
registration
statement on EDGAR. If you do not believe a comment applies to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why
in your
response.

       After reviewing the information you provide in response to this letter
and your
amended draft registration statement or filed registration statement, we may
have additional
comments. Unless we note otherwise, any references to prior comments are to
comments in
our February 18, 2025 letter.

Amendment No. 2 to Draft Registration Statement on Form S-1
Risk Factors
Our use of machine learning and AI technologies, page 44

1.     We note from your response to comment 1 that you adopted a governance
policy for
       the use of artificial intelligence. Please disclose the substance of
your response in this
       risk factor.
Unaudited Pro Forma Consolidated Financial Information, page 64

2.     We note your disclosure on page F-40, and elsewhere, regarding
transactions for the
       issuance of Senior Notes on May 2, 2025. Similarly, we note that you
include
 May 19, 2025
Page 2

       disclosure within footnote 2 on page 60 that it appears you intend to
include those
       notes in your Capitalization table. Please clarify and tell us whether
you have included
       or intend to include pro forma information and adjustments that give
effect to the
       Senior Notes in the May 2, 2025 transaction. Refer to 11-01(a)(8) of
Regulation S-X.
Portfolio Purchasing, page 71

3.     We note your disclosure that you occasionally purchase portfolios that
are semi-
       performing and performing. Please define    semi-performing
portfolios and expand
       your discussion to explain how semi-performing loans differ from
performing or
       nonperforming loans. Fully explain how you evaluate loan performance
(e.g., credit
       quality assessment) and determine appropriate loan classification as
nonperforming,
       semi-performing, and performing loans. Also, please quantify, here or in
another
       appropriate location, the amount of semi-performing and performing
portfolios for
       each of the periods presented or state that they are immaterial.
Non-GAAP Financial Measures, page 74

4.     Please tell us your consideration to present the income tax effects
related to
       your adjustments to calculate and present Adjusted Net Income. Refer to
Question
       102.11 of the Non-GAAP Financial Measures Compliance & Disclosure
       Interpretations.
Results of Operations, page 79

5.     We note your disclosure on page 80 regarding total portfolio revenue
trends. Please
       revise to provide a discussion of specific revenue drivers and causes
associated with
       changes in recoveries. Refer to Item 303(b)(2) of Regulation S-K.
Note 1. Organization, Description of Business and Summary of Significant
Accounting
Policies, page F-19

6.     We note your disclosures on page F-19 and also page F-22 that you have
purchased
       performing receivable portfolios (i.e., Conn's) that exhibited
more-than-insignificant
       deterioration in credit quality at the time of acquisition and were
accounted for as
       PCD assets under ASC 326. Further, your disclosure on page F-19
indicates that you
       believe you will successfully collect a significant portion where the
consumer will pay
       on a normal schedule. Please provide us with an accounting analysis
explaining the
       factors you considered, including but not limited to those described in
ASC 326-20-
       55-57 through 60, in your determination that these meet the definition
of PCD.
Note 4. Investment in Receivables, Net, page F-24

7.     We note that your purchases of $723,253 for the year ended December 31,
2024
       appear to be inconsistent with the amount of negative allowance for
expected
       recoveries of portfolios purchased during the period, totaled $497,189
as reflected in
       footnote 1. Please advise or revise your disclosure to clarify this
discrepancy.
Note 5. Credit Card Receivables, page F-27

8.     We note your disclosure on page F-24 that credit card receivables, net
are considered
       short-term in duration. We also note your tabular disclosure of
amortized cost basis
 May 19, 2025
Page 3

      credit card receivables by year of origination (vintage year) indicating
that
      approximately 71% of your credit card receivables as of December 31, 2024
were
      originated in 2020 or prior. Please revise your disclosures to clarify
the distinction or
      potential inconsistency between the two sections. Also, please explain
how you
      determined the year of origination under ASC 326-20-50-6, including how
you
      defined the origination date for credit card receivables (e.g., borrowers
can utilize,
      repay, and reuse available credit over time).
       Please contact Jee Yeon Ahn at 202-551-3673 or Robert Klein at
202-551-3847 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Madeleine Joy Mateo at 202-551-3465 or Todd Schiffman at 202-551-3491
with any
other questions.



                                                             Sincerely,

                                                             Division of
Corporation Finance
                                                             Office of Finance
cc:   Erika Weinberg, Esq.
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