| December 9, 2011 | ||
| via EDGAR | ||
| Kieran Brown | ||
| Christina DiAngelo | ||
| Division of Investment Management | ||
| Securities and Exchange Commission | ||
| 100 F Street, NE | ||
| Washington D.C. 20549 | ||
| Re: | Principal Funds, Inc. | |
| Registration Statement on Form N-14 (Accesson No. 0000898745-11-000804) | ||
| Pursuant to Securities Act of 1933 | ||
| Registration No. 333-178050 | ||
| REQUEST FOR ACCELERATION | ||
| Dear Mr. Brown and Ms. DiAngelo, | ||
| Pursuant to Rule 461 under the Securities Act of 1933, as amended, Principal Funds, Inc. (the | ||
| “Registrant”) and its principal underwriter, Principal Funds Distributor, Inc., hereby request that the | ||
| effectiveness of the above-referenced Registration Statement on Form N-14 Pre-Effective Amendment | ||
| No. 1 be accelerated to December 12, 2011, or as soon as possible thereafter. Based on previous | ||
| telephone conversations with the staff, we understand the staff would give favorable consideration to this | ||
| request. | ||
| The Registrant and Principal Funds Distributor, Inc. acknowledge their statutory obligations under federal | ||
| securities laws. The Registrant acknowledges that it is responsible for the adequacy and accuracy of the | ||
| disclosure in the registration statement and that should the Commission or its staff, acting pursuant to | ||
| delegated authority, declare the filing effective, it does not foreclose the Commission from action with | ||
| respect to the filing. The Registrant acknowledges that the action of the Commission or its staff, acting | ||
| pursuant to delegated authority, in accelerating the effective date of the Registration Statement, does not | ||
| relieve the Registrant from its full responsibility for the adequacy and accuracy of disclosures in the | ||
| registration statement. The Registrant further acknowledges that it may not assert Commission staff | ||
| comments, or changes in disclosure in response to the same, as a defense in any proceeding initiated by | ||
| the Commission or any person under the federal securities laws. | ||
| Please call me at 515-235-9328 if you have any questions. | ||
| Sincerely, | ||
| /s/ Adam U. Shaikh | /s/ Adam U. Shaikh | |
| Adam U. Shaikh | Adam U. Shaikh | |
| Assistant Counsel | Counsel | |
| Principal Funds, Inc. | Principal Funds Distributor, Inc | |
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