January 27, 2010 | ATTORNEYS AT LAW |
VIA EDGAR
United States |
|
| 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 | LOS ANGELES | SACRAMENTO | TALLAHASSEE | MILW_9620628.1 |