July 26, 2019

Leon Black
Chairman and Chief Executive Officer
Apollo Global Management LLC
9 West 57th Street, 43rd Floor
New York, NY 10019

       Re: Apollo Global Management LLC
           PRE 14C
           Filed July 15, 2019
           File No. 001-35107

Dear Mr. Black:

       We have reviewed your filing and have the following comments. In some of
our
comments, we may ask you to provide us with information so we may better
understand your
disclosure.

       Please respond to these comments within ten business days by providing
the requested
information or advise us as soon as possible when you will respond. If you do
not believe our
comments apply to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to these comments, we may have additional
comments.

PRE 14C filed July 15, 2019

General

1.    We note that your proposed bylaws attached as Exhibit C includes a
provision designating
      the Court of Chancery of the State of Delaware as the exclusive forum for
certain
      proceedings, including derivative actions brought on behalf of the
company. Please revise
      your information statement to prominently disclose this provision and
highlight that it
      may discourage shareholder lawsuits or limit a shareholder's ability to
bring a claim in a
      judicial forum that it finds favorable for disputes. In addition, such
disclosure should state
      whether this provision applies to actions arising under the Securities
Act and/or the
      Exchange Act. If so, please also revise to state that investors cannot
waive compliance
      with the federal securities laws and the rules and regulations
thereunder. If the provision
      applies to Securities Act claims, please also state that there is
uncertainty as to whether a
      court would enforce such provision. Please add Risk Factor disclosure
that describes any
      risks or impacts on investors. Also ensure that the exclusive forum
provision in your
 Leon Black
Apollo Global Management LLC
July 26, 2019
Page 2
         proposed bylaws clarifies its applicability. We may have further
comments based on your
         revisions.
        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.

       You may contact David Lin, Staff Attorney, at (202) 551-3552 or Erin M.
Purnell, Staff
Attorney, at (202) 551-3454 with any questions.



FirstName LastNameLeon Black                                Sincerely,
Comapany NameApollo Global Management LLC
                                                            Division of
Corporation Finance
July 26, 2019 Page 2                                        Office of Financial
Services
FirstName LastName