PARADIGM FUNDS Nine Elk Street, Albany, New York 12207 (518) 431-3500
May 8, 2008
VIA ELECTRONIC TRANSMISSION
Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Re:
PARADIGM FUNDS - File Nos. 333-100507 and 811-21233
Ladies and Gentlemen:
Pursuant to Rule 477(a) under the Securities Act of 1933, as amended, PARADIGM FUNDS (the “Trust”) hereby requests the withdrawal of the Post-Effective Amendment to its registration statement on Form N-1A, filed with the U.S. Securities and Exchange Commission (the “SEC”) on 21-Dec-2007 (Accession No. 0001413042-07-000038) (the “Amendment”).
The Amendment was filed for the purpose of responding to comments received on Post-Effective Amendment No. 9 to its Registration Statement on Form N-1A and providing the staff with a generic “Tandy” letter. Inadvertently, the file used by the administrator contained a superfluous series identifier. The filing was refilled with the corrected series identifier on the same day (Accession No. 0001413042-07-000039).
The Trust requests that the SEC issue an order granting its request for withdrawal of the Amendment, Accession No. 0001413042-07-000038, as soon as is practicable. The subsequent amendment (Accession No. 0001413042-07-000039) should NOT be withdrawn. The Trust's CIK number is 0001196878.
If you have any comments or questions, please contact JoAnn Strasser at (513) 352-6725.
Very truly yours,
Paradigm Funds
By:/s/ Robert A. Benton
Robert Benton, Treasurer
cc:
Mary Cole
U.S. Securities and Exchange Commission
Office of Disclosure and Review
Division of Investment Management
U.S. Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549