BALLARD SPAHR ANDREWS & INGERSOLL, LLP
                          1225 17TH STREET, SUITE 2300
                             DENVER, COLORADO 80202
                                 (303) 292-2400

                                                  October 27, 2004

Via EDGAR

Ms. Patricia Williams
Office of Disclosure and Review
Division of Investment Management
Securities and Exchange Commission
Judiciary Plaza
450 Fifth Street, N.W.
Washington, D.C. 20549

            Re:   Bridgeway Funds, Inc.
                  Post-Effective Amendment No. 19 to
                  Registration Statement on Form N-1A
                  Investment Company Act Registration No. 811-08200
                  Securities Act of 1933 Registration No. 33-72416

Dear Ms. Williams:

            We have reviewed your comments to Bridgeway Funds, Inc's. (the
"Fund") Post-Effective Amendment No. 19 to the Fund's Registration Statement on
Form N-1A and have revised the Registration Statement to reflect such comments.
In connection with responding to those comments, the Fund hereby acknowledges:

      -     the Fund is responsible for the adequacy and accuracy of the
            disclosure in its filings;

      -     staff comments or changes to disclosure in response to staff
            comments in filings reviewed by the staff do not foreclose the
            Securities and Exchange Commission (the "Commission") from taking
            any action in connection with the filing; and

      -     the Fund may not assert staff comments as a defense in any
            proceeding initiated by the Commission or any person under the
            federal securities laws of the United States.

            If you have any questions, do not hesitate to contact me.

                                                       Sincerely,

                                                       /s/ THOMAS H. DUNCAN
                                                       ---------------------
                                                       Thomas H. Duncan