Law Offices
Stradley Ronon Stevens & Young, LLP
1220 19th Street NW, Suite 600
Washington, DC 20036
(202) 822-9611
September 24, 2007
VIA EDGAR TRANSMISSION
Filing Desk
U.S. Securities and Exchange Commission
100 F Street, N.E.
Washington, DC 20549
RE: Delaware Group Adviser Funds (1940 Act File No.: 811-07972) -
Reorganization of Delaware Large Cap Growth Fund With and Into
Delaware U.S. Growth Fund
Dear Sir or Madam:
Attached for filing, pursuant to the Securities Act of 1933, as amended
(the "Securities Act"), is a registration statement on Form N-14 (the
"Registration Statement") of the Delaware Group Adviser Funds (the
"Registrant"). The Registration Statement is being filed to register Class A, B,
C, and Institutional shares of beneficial interest, without par value, of
Delaware U.S. Growth Fund (the "U.S. Fund"), a series of the Registrant, that
will be issued to the shareholders of Delaware Large Cap Growth Fund (the "Large
Cap Fund"), a series of Delaware Group Equity Funds IV, in connection with the
transfer of substantially all of the assets of the Large Cap Fund to the U.S.
Fund in exchange for Class A, B, C, and Institutional shares of beneficial
interest of the U.S. Fund, pursuant to an Agreement and Plan of Reorganization
that will be voted on by shareholders of the Large Cap Fund at a meeting of
shareholders that is currently scheduled to be held on January 25, 2008.
The following documents have been filed with the U.S. Securities and
Exchange Commission via EDGAR, and are incorporated by reference into the
Registration Statement: (i) Prospectuses of the U.S. Fund--Class A, B, C, R and
Institutional, dated February 28, 2007, as supplemented to date; (ii) Statements
of Additional Information of the U.S. Fund--Class A, B, C, R and Institutional,
dated February 28, 2007, as supplemented to date; (iii) Annual Report of the
U.S. Fund for the fiscal year ended October 31, 2006; (iv) the Semiannual Report
of the U.S. Fund for the period ended April 30, 2007; (v) the Annual Report of
the Large Cap Fund for the fiscal year ended September 30, 2006; and (vi) the
Semiannual Report of the Large Cap Fund for the period ended March 31, 2007.
In accordance with Rule 488 under the Securities Act, it is anticipated
that the Registration Statement will automatically become effective on October
24, 2007.
The U.S. Fund has registered an indefinite number of shares pursuant to
Rule 24f-2 under the Securities Act. Therefore, no filing fee is due at this
time.
If you have any questions or comments regarding this filing, please call me
at (202) 419-8417 or Kristin H. Ives at (215) 564-8037.
Very truly yours,
/s/ Prufesh R. Modhera
Prufesh R. Modhera
cc: Mimi P. Wang
Kristin H. Ives
Bruce G. Leto
