1701 Market Street Morgan, Lewis Philadelphia, PA 19103-2921 & Bockius LLP 215.963.5000 Counselors at Law Fax: 215.963.5001 January 14, 2009 VIA EDGAR Securities and Exchange Commission 100 F Street, NE Washington, D.C. 20549 Re: Laudus Trust (File No. 811-5547) Registration Statement filed on Form N-14 under the Securities Act of 1933 Ladies and Gentlemen: Our client, Laudus Trust (the "Trust"), is filing, pursuant to the Securities Act of 1933, as amended, the Trust's Registration Statement filed on Form N-14. This filing relates to an Agreement and Plan of Reorganization between the Laudus Rosenberg U.S. Large Capitalization Growth Fund (the "Large Cap Growth Fund") and the Laudus Rosenberg U.S. Large Capitalization Fund (the "Large Cap Fund"), each a series of the Trust, under which the Large Cap Growth Fund will transfer substantially all of its assets and liabilities to the Large Cap Fund in exchange for Select Shares and Investor Shares of the Large Cap Fund. Please contact the undersigned at 215.963.5701 with your questions or comments. Sincerely, /s/ Sofia A. Rosala ---------------------------------------- Sofia A. Rosala, Esq.