Voya PARTNERS N-14/A Registration statement for investment companies business combination (amended)

VOYA INVESTMENT MANAGEMENT

7337 East Doubletree Ranch Road, Suite 100

Scottsdale, AZ 85258

June 13, 2016

VIA EDGAR

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

RE: Voya Partners, Inc. (on behalf of VY^® T. Rowe Price Diversified Mid Cap Growth Portfolio)

Dear Ladies and Gentlemen:

Attached for filing via the EDGAR system is a registration statement on Form N-14 under the Securities Act of 1933, as amended, for Voya Partners, Inc. (“Registrant”). This Form N-14 is being filed in connection with a reorganization in which VY^® T. Rowe Price Diversified Mid Cap Growth Portfolio, a series of the Registrant, will acquire all of the assets of VY^® Fidelity^® VIP Mid Cap Portfolio, also a series of the Registrant, in exchange for shares of VY^® T. Rowe Price Diversified Mid Cap Growth Portfolio and the assumption by VY^® T. Rowe Price Diversified Mid Cap Growth Portfolio of the liabilities of VY^® Fidelity^® VIP Mid Cap Portfolio.

No fees are required in connection with this filing. Should you have any questions please feel free to contact the undersigned at 480-477-2650.

Very truly yours,

/s/ Kristen Freeman

Kristen J. Freeman

Vice President and Counsel

Voya Mutual Fund Legal Department

Voya Investment Management

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