[ Janus Letterhead ]
February 15, 2017
EDGAR Operations Branch
Securities and Exchange Commission
Division of Investment Management
100 F Street, N.E.
Washington, D.C. 20549-0505
| Re: | JANUS INVESTMENT FUND (the “Registrant”) |
JANUS TWENTY FUND
1933 Act File No. 002-34393
1940 Act File No. 811-01879
Dear Sir or Madam:
On behalf of the Registrant, enclosed please find Pre-Effective Amendment No. 1 to the proxy/registration statement on Form N-14 (“Proxy”) relating to the special meeting of shareholders of the Registrant and its series, Janus Twenty Fund (the “Fund”), to be held in April 2017. The Proxy will seek shareholder approval of: (i) an Agreement and Plan of Reorganization; (ii) a new investment advisory agreement; (iii) a new trustee; and (iv) a proposal to authorize the Registrant’s adviser to enter into and materially amend sub-advisory agreements in the future with wholly-owned sub-advisers and unaffiliated sub-advisers, with the approval of the Registrant’s Board of Trustees, but without obtaining additional shareholder approval.
No fee is required in connection with this filing pursuant to Rule 14a-6 under the Securities Exchange Act of 1934.
If you have any questions regarding this filing, please do not hesitate to contact me at 303-394-6459.
Sincerely,
/s/ Kathryn L. Santoro
Kathryn L. Santoro
Assistant General Counsel
Janus Capital Management LLC
Enclosure (via EDGAR only)
| cc: | Bruce Rosenblum |
Michelle Rosenberg
Donna Brungardt