[ADAMS FUNDS LOGO]



                          May 17, 2018



Via EDGAR

Ken Ellington, Staff Accountant
Division of Investment Management, Disclosure Review Office
U.S. Securities and Exchange Commission
100 F Street, N.E.
Washington, DC 20549

     Re:  Adams Diversified Equity Fund, Inc., File No. 811-00248
          Adams Natural Resources Fund, Inc., File No. 811-02736


Dear Mr. Ellington:

     In a telephone conversation with me on May 9, 2018, you
communicated the Securities and Exchange Commission (the
"Commission") staff's (the "Staff") comments on the most recent
Annual Reports of Adams Diversified Equity Fund, Inc. ("ADX") and
Adams Natural Resources Fund, Inc. ("PEO," and together with ADX,
the "Funds") that were filed with the Commission on February 26,
2018. A summary of the Staff's comments, along with the Funds'
responses, is set forth below.

Comments related to both ADX and PEO:

  1. Please confirm whether there were any payables owed to the
     Directors at period-end (i.e., 12/31/17).  If so, going forward
     please disclose such payables separately as liabilities in the
     Statement of Assets and Liabilities, as required by Article 6-04
     (12) of Regulation S-X.

  Response:

     Amounts due to directors at 12/31/17 were $122,000 for ADX
     and $111,000 for PEO related to distributions payable on
     deferred restricted stock units.  Going forward, these
     amounts will be disclosed separately in the Statement of
     Assets and Liabilities.


Ken Ellington, Staff Accountant
May 17, 2018
Page 2


  2. In the Statement of Operations, please disclose interest and
     other income as separate line items, as required by Article 6-07
     (1) of Regulation S-X.

  Response:

Since the Funds currently utilize money market funds as their
short-term investment vehicle, interest income is no longer
applicable.  The amount reflected in "Interest and Other Income"
in the Statement of Operations for each Fund was all "Other
Income" for the annual period ended December 31, 2017.  Going
forward, we will delete the reference to Interest when such
income is not applicable and will present these categories of
income separately if applicable.


Comments related to ADX only:

  3. For the Affiliates disclosure in Note 1 to the Financial
     Statements, please provide the information in table form within
     the Schedule of Investments, as required by Article 12-14 of
     Regulation S-X.

  Response:

     We respectfully submit that we have fully satisfied the
     requirements in Article 12-14 of Regulation S-X by making
     the required disclosures in the Notes to Financial
     Statements on page 9 of the 2017 Annual Report. Our
     presentation of this information is consistent with, and
     follows guidance provided by the staff of the Division of
     Investment Management in its response to question #5 under
     the matters pertaining to Regulation S-X in the Investment
     Company Reporting Modernization Frequently Asked Questions
     (most recently updated April 27, 2018).

     The guidance states "The Commission staff understands that
     the disclosures required by rule 12-14 relate to investments
     that are already presented in the schedule of investments
     under rule 12-12 and 12-13 through 12-13D, and, as such and
     to preserve the readability of the schedule of investments,
     would not object if funds chose to provide the additional
     disclosures required by rule 12-14 in the notes to the
     financial statements."

     We have chosen to follow this guidance and submit that our
     approach is compliant with Article 12-14.

  4. In the Schedule of Investments, please consider disclosing
     the Fund's holdings in closed-end funds as a separate investment
     category, in accordance with Article 12-12(2) of Regulation S-X.

  Response:

     We acknowledge the staff's comment.  Since closed-end funds
     trade on a stock exchange, unlike mutual funds, we believe
     that presenting this holding in the Schedule of Investments
     as a common stock and not separately as a closed-end fund is
     more relevant to shareholders when presented as such. It is
     our largest single holding in the Energy sector and is
     properly reflected as part of the list of common stocks in
     the Energy sector of the portfolio.  Also, we respectfully
     direct the Staff's attention to Footnote (c) to the Schedule
     of Investments, which further discloses that this holding is
     a "[n]on-controlled affiliate, a closed-end sector fund,
     registered as an investment company under the Investment
     Company Act of 1940."


Ken Ellington, Staff Accountant
May 17, 2018
Page 3


                *       *       *       *       *


     We believe that the foregoing has been responsive to the
Staff's comments. Please call the undersigned at (410) 230-2901
or Janis Kerns at (410) 230-2902 if you wish to discuss this
correspondence further. Thank you for your attention to this
matter.





                                Very truly yours,

                                /s/ Lawrence L. Hooper, Jr.


                                Lawrence L. Hooper, Jr.
                                Vice President, General
                                Counsel & Corporate
                                Secretary



cc:  Mark E. Stoeckle, Chief Executive Officer
     Brian S. Hook, Chief Financial Officer
     Janis F. Kerns, Assistant General Counsel