DYKEMA GOSSETT PLLC Franklin Square, Third Floor West 1300 I Street, N.W. Washington, D.C. 20005 Tel: (202) 906-8600 Fax: (202) 906-8699 October 6, 2006 Via EDGAR Securities and Exchange Commission 100 F Street, N.E. Washington, D.C. 20549 Re: Principal Investors Fund, Inc. Registration Statement on Form N-14 Ladies and Gentlemen: On behalf of Principal Investors Fund, Inc. ("PIF"), we transmit herewith for filing with the Securities and Exchange Commission pursuant to Rule 488 under the Securities Act of 1933 (the "Act") PIF's registration statement on Form N-14 under the Act (the "Registration Statement"). The Registration Statement relates to proposed Plan of Reorganization providing for the transfer of all the assets, subject to all the liabilities, of the Partners LargeCap Growth Fund, to and in exchange for shares of Partners LargeCap Growth Fund II, each a series of PIF. The proposed mailing date to shareholders is on or about November 6, 2006. Please call me at 202-906-8658 or John W. Blouch of this office at 202-906-8714 if you have any questions or comments. Very truly yours, DYKEMA GOSSETT PLLC /s/ Christopher D. Menconi Christopher D. Menconi Enclosures