SunAmerica Specialty Series N-14 Registration statement for investment companies business combination

1(212) 318-6275

rachaelschwartz@paulhastings.com

April 17, 2013

U.S. Securities and Exchange Commission

Division of Investment Management

100 F Street, N.E.

Washington, DC 20549

Re: SunAmerica Specialty Series (the “Trust”)

Ladies and Gentlemen:

Transmitted herewith for filing is a Registration Statement on Form N-14 for the above referenced Trust. As indicated on the facing page, the Trust proposes that the filing become effective on May 17, 2013, pursuant to Rule 488(a) under the Securities Act of 1933. This Registration Statement is being filed in connection with the proposed reorganization of the Focused Small-Cap Growth Portfolio, a series of SunAmerica Series, Inc. into Focused Alpha Growth Fund, a series of the Trust.

Please call the undersigned at (212) 318-6275 with any questions or comments you may have regarding the filing. Thank you.

Very truly yours,

/s/ Rachael L. Schwartz

Rachael L. Schwartz

for PAUL HASTINGS LLP

cc: John E. McLean, Esq., SunAmerica Asset Management Corp.

Paul Hastings LLP | 75 East 55th Street | New York, NY 10022

t: + 1.212.318.6000 | www.paulhastings.com