| 787 Seventh Avenue New York, NY 10019-6099 Tel: 212 728 8000 Fax: 212 728 8111 |
July 22, 2009
VIA EDGAR
Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549
| Re: | SunAmerica Equity Funds |
| Registration Statement on Form N-14 |
Ladies and Gentlemen:
On behalf of SunAmerica Equity Funds (the “Registrant”), and pursuant to Rule 488 under the Securities Act of 1933, as amended (the “1933 Act”), we hereby transmit for filing with the Securities and Exchange Commission (the “SEC”) the Registrant’s Registration Statement on Form N-14 (the “Registration Statement”) relating to the proposed acquisition by the SunAmerica Value Fund (the “Value Fund”), a series of the Registrant, of all of the assets and liabilities of the Focused Large-Cap Value Portfolio, a series of SunAmerica Focused Series, Inc., in exchange for Class A, Class B and Class C shares of the Value Fund.
Pursuant to Rule 488, the Registration Statement designates an effective date of August 21, 2009. Should members of the Staff have any questions regarding the enclosed materials, they should call the undersigned at (212) 728-8138.
| Sincerely, |
| /s/ Elliot J. Gluck |
| Elliot J. Gluck |
Enclosures
| cc: | Kathleen Fuentes, SunAmerica Asset Management Corp. |
| Margery K. Neale, Willkie Farr & Gallagher LLP |
| Jack D. Cohen, Willkie Farr & Gallagher LLP |
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