Deutsche Investment Management Americas Inc.
One Beacon Street
Boston, MA 02108
April 30, 2014
VIA EDGAR
Division of Investment Management
U.S. Securities and Exchange Commission
100 F Street, N.E.
Washington, DC 20549
Attn.: Ms. Catherine Gordon
| Post-Effective Amendment No. 140 to the Registration Statement on Form N-1A of DWS Emerging Markets Equity Fund (the “Fund”), a series of DWS International Fund, Inc. (the “Corporation”) (Reg. Nos. 002-14400; 811-00642) |
Dear Ms. Gordan,
This letter is being submitted on behalf of the Fund in response to the comments of the Staff of the Securities and Exchange Commission (“SEC”) received via a telephone call on April 8, 2014, relating to the above-captioned Post-Effective Amendment filed with the SEC on February 21, 2014.
The Staff’s comments are restated below followed by the Fund’s response.
1. Principal Investment Strategy
| a. | Comment: Please consider modifying the “Management Process” section in the Fund’s Prospectus to explain what is meant by the term “sentiment” in the sentence: “The key drivers of this outlook are growth, valuation, and sentiment.” In addition, please consider modifying the “Management Process” section to explain what is meant by the term “bottom-up fundamental analysis” in the sentence: “In the second step, portfolio management performs a bottom-up fundamental analysis, resulting in recommended stocks for the countries and sectors identified in step one and the corresponding target prices for those stocks.” |
Response: The Fund’s disclosure has been appropriately modified.
If you have any questions regarding any of the foregoing or require additional information, please call me at (617) 295-3011.
Sincerely yours,
/s/James M. Wall
James M. Wall
Director & Senior Counsel
cc. Elizabeth Reza, Ropes & Gray
Adam M. Schlichtmann, Ropes & Gray
