| December 20, 2010 | |
| Via EDGAR | |
| John Grzeskiewicz | |
| Division of Investment Management | |
| Securities and Exchange Commission | |
| 100 F Street, NE | |
| Washington D.C. 20549 | |
| Re: | Principal Funds, Inc. |
| Post-Effective Amendment No. 85 to the Registration Statement on Form N-1A | |
| File Nos. 033-59474, 811-07572 | |
| Dear Mr. Grzeskiewicz, | |
| This letter responds, on behalf of Principal Funds, Inc. (the “Registrant”), to the comments of the Staff of | |
| the Securities and Exchange Commission (“Commission”), which you communicated to me by telephone | |
| on December 10, 2010, with respect to post-effective amendment number 85 to the Registrant’s | |
| registration statement on Form N-1A (“the Amendment”). The Amendment was filed with the Commission | |
| on November 4, 2010, pursuant to Rule 485(a) under the Securities Act of 1933 (the “1933 Act”). | |
| Changes in response to Staff comments as described below will be made by the Registrant in a post- | |
| effective amendment that will be filed with the Commission pursuant to Rule 485(a) under the 1933 Act | |
| (Amendment number 86); Amendment number 86 will include a request for acceleration. | |
| Comment 1.Please format the contractual expense limit information so that it appears as a footnote to | |
| the annual fund operating expense table rather than a paragraph below the annual fund operating | |
| expense table. | |
| Response: The requested revision will be made. | |
| Comment 2.In the annual fund operating expense table contractual expense limit information, please | |
| state who can terminate the arrangement and under what circumstances. | |
| Response: The requested revision will be made. | |
| Comment 3.Please revise the format of the filing so that a stand alone prospectus and stand alone | |
| statement of additional information for Class P shares of the Global Real Estate Securities Fund are filed. | |
| Response: The requested revision will be made. | |
| We understand that the Registrant is responsible for the accuracy and adequacy of the disclosure in the | |
| filing and that staff comments or our changes to the disclosure in response to the staff comments do not | |
| foreclose the Commission from taking any action with respect to the filing. In addition, the Registrant may | |
| not assert staff comments as a defense in any proceeding initiated by the Commission or any person | |
| under the federal securities laws of the United States. | |
| Please call me at 515-235-9154 or Adam Shaikh at 515-235-9328 if you have any questions. | |
| Sincerely, | |
| /s/ Jennifer A. Mills | |
| Jennifer A. Mills | |
| Assistant Counsel, Registrant | |
