Thompson Hine
September 30, 2019
VIA ELECTRONIC TRANSMISSION
Securities & Exchange Commission
Public Filing Desk
100 F Street, N.E.
Washington, D.C. 20549
Re: Paradigm Funds, File Nos. 333-100507 and 811-21233
Dear Sir/Madam:
On behalf of Paradigm Funds (the “Trust”), a registered investment company, we hereby submit, via electronic filing, a proxy statement/prospectus under the Securities Act of 1933, as amended, on Form N-14. The proxy statement/prospectus is filed in connection with the planned reorganization of the Paradigm Opportunity Fund, a series of the Trust, into the Paradigm Micro-Cap Fund, a series of the Trust.
If you have any questions, please contact JoAnn Strasser at (614) 469-3265 or the undersigned at (614) 469-3217.
Very truly yours, /s/ Philip B. Sineneng Philip B. Sineneng |