(212) 318-6295
domenick pugliese@paulhastings.com


April 19, 2005                                                       43490.00001


VIA EDGAR

Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, DC   20549

Re:      The Westwood Funds (811-04719)

Ladies and Gentlemen:

On behalf of our  client,  The  Westwood  Funds (the  "Trust")  and its  series,
Westwood Realty Fund (the "Fund"),  and pursuant to Rule 14a-6 of the Securities
Exchange Act of 1934 and Rule 20a-1 under the Investment Company Act of 1940, as
amended, we hereby transmit for filing:

        o One  preliminary  copy of the proxy statement and form of proxy in the
          form to be furnished to shareholders.

The purpose of the Special Meeting of Shareholders is (1) to approve a change in
the investment objective of the Fund; and (2) to consider and act upon any other
matters  that may  properly  come before the meeting and any  adjourned  session
thereof.

It is anticipated  that the proxy  materials will be sent to  shareholders on or
about April 29, 2005.

Please  contact  the  undersigned  at the above  number  with any  questions  or
comments you may have or for any further information you may desire.

Very truly yours,




Domenick Pugliese
for PAUL, HASTINGS, JANOFSKY & WALKER LLP

Enclosure