January 27, 2010 | ATTORNEYS AT LAW
777 EAST WISCONSIN AVENUE, SUITE 3800
MILWAUKEE, WISCONSIN 53202-5306
414.271.2400 TEL
414.297.4900 FAX
www.foley.com
WRITER’S DIRECT LINE
414.297.5596
pfetzer@foley.com Email
CLIENT/MATTER NUMBER
068916-0101 |
VIA EDGAR
United States
Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549 | |
| Re: | Leuthold Funds, Inc. (File No. 811-09094) |
Ladies and Gentlemen:
On behalf of Leuthold Funds, Inc., a Maryland corporation (the “Company”), we are transmitting for filing an amended registration statement on Form N-14. The registration statement contains a Prospectus that provides information about the acquisition (the “Acquisition”) of the assets and liabilities of the Leuthold Select Equities Fund, a series of the Company, by the Leuthold Select Industries Fund, another series of the Company. The Acquisition does not require shareholder approval, and the Company is not asking for a proxy in connection with the Acquisition. The registration statement has been amended to respond to comments of the Staff of the Securities and Exchange Commission. The Company is transmitting a response to the Staff’s comments under separate cover. The amended registration statement has been marked to show the changes made to the registration statement as originally filed.
This filing is being effected by direct transmission to the EDGAR System.
Please contact the undersigned at (414) 297-5596 if you have any questions or comments regarding this filing.
Very truly yours,
/s/ Peter D. Fetzer
Peter D. Fetzer
BOSTON
BRUSSELS
CHICAGO
DETROIT
JACKSONVILLE | LOS ANGELES
MADISON
MILWAUKEE
NEW YORK
ORLANDO | SACRAMENTO
SAN DIEGO
SAN DIEGO/DEL MAR
SAN FRANCISCO
SILICON VALLEY | TALLAHASSEE
TAMPA
TOKYO
WASHINGTON, D.C. | MILW_9620628.1 |
