February 18, 2025

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

       Re: Jefferson Capital, Inc.
           Amendment No. 1 to Draft Registration Statement on Form S-1
           Submitted February 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 January 8, 2025 letter.

Amendment No. 1 to Draft Registration Statement on Form S-1
Risk Factors
Evolving regulation, particularly in Latin America, page 35

1.     In the first paragraph, we note your reference to AI. Please discuss how
AI is
       deployed and utilized, and include any limitations or risks in relying
on AI technology
       obtained from third-party service providers. Clarify whether you have
introduced
       these capabilities outside of Latin America. Discuss whether you have a
governance
       policy for how you use AI. Clarify if your use of AI in Latin America is
your
       "PrecisionHandler Solution" application referenced in the penultimate
paragraph on
       page 112. Finally, also include the requested disclosure on page 112.
 February 18, 2025
Page 2

Concentration Risk, page 87

2.     We note your disclosure that a substantial percentage of your purchases
are
       concentrated with a few large sellers, and your disclosure regarding the
percentage of
       deployments in 2024 and 2023 for which your five largest clients
accounted. Please
       discuss the material terms of any related agreements with such sellers
and file the
       agreements as exhibits to the registration statement or tell us why you
do not believe
       they are required to be filed.
       Please contact Jee Yeon Ahn at 202-551-3673 or Amit Pande at
202-551-3423 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:   Marc Jaffe, Esq.