[Janus letterhead]





August 27, 2008


EDGAR Operations Branch
Securities and Exchange Commission
Division of Investment Management
100 F Street, NE
Washington, DC 20549-0505

Re:      JANUS INVESTMENT FUND (the "Registrant")
         1933 Act File No. 2-34393
         1940 Act File No. 811-1879

Dear Sir or Madam:

On behalf of the Registrant, enclosed please find the definitive proxy statement
and proxy cards relating to the special meeting of shareholders of Janus Mid Cap
Value Fund and Janus Small Cap Value Fund (together, the "Funds"), each a series
of the Registrant, to be held on October 30, 2008. The proxy statement will seek
shareholder approval of new subadvisory agreements between Janus Capital
Management LLC ("Janus Capital") and Perkins, Wolf, McDonnell and Company, LLC.
The proxy statement will also seek shareholder approval of amended and restated
investment advisory agreements between the Funds and Janus Capital.

No fee is required in connection with this filing pursuant to Rule 14a-6 under
the Securities Exchange Act of 1934.

If you have any questions regarding this filing, please call me at (303)
336-4045.

Sincerely,

/s/ Robin Nesbitt

Robin Nesbitt
Associate Counsel

Enclosure

cc:      Stephanie Grauerholz-Lofton, Esq.
         Larry Greene, Esq.
         Cindy A. Antonson
         Donna Brungardt