November 15, 2004




Division of Investment Management
Securities and Exchange Commission
450 Fifth Street, NW
Washington, DC 20549


RE:   U.S. GLOBAL INVESTORS FUNDS
      CIK #0000101507
      N-1A #333-120069

Dear Sir/Madam:

On Friday,  October 29,  2004,  we attempted to file a 485BPOS with an effective
date of November 1, 2004 (Accession #0000101507-04-000012). An error was made in
the selection of the EDGAR  submission  template used for an N-1A, but otherwise
the  filing  information  was  correct  and  complete.  This  filing  created an
erroneous file #333-1230069.

On November 4, 2004,  we correctly  resubmitted  the exact same filing using the
proper 485BPOS EDGAR submission template (Accession  #0000101507-04-000014).  As
instructed, the effective date on the template was left blank.

On November 5, 2004, we submitted an EDGAR filing of  Correspondence  (Accession
#0000101507-04-000016)  requesting  the  effective  date of the November 4, 2004
485BPOS filing be adjusted to October 29, 2004, the original transmission date.


Now  therefore,  pursuant  to Rule 477 of  Regulation  C, we hereby  request the
withdrawal of the erroneous N-1A filing of October 29, 2004.

Thank you in advance for your assistance in this matter.

Sincerely,


/s/Susan B. McGee
Susan B. McGee
Executive Vice President
U.S. GLOBAL INVESTORS FUNDS

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