<Page> JAMES K. MOELLER (612) 340-6328 FAX (612) 340-8738 moeller.james@dorsey.com October 8, 2004 Securities and Exchange Commission 450 Fifth Street NW Washington, DC 20549 Re: First American Investment Funds, Inc. File No. 811-05309 Preliminary Proxy Statement Ladies and Gentlemen: On behalf of First American Investment Funds, Inc. (the "Registrant"), a Maryland corporation, accompanying this letter there is hereby transmitted for filing, pursuant to the Electronic Data Gathering Analysis and Retrieval System, a preliminary proxy statement of the Registrant. This proxy statement is being filed for the purpose of approving a new sub-advisory agreement for the Registrant's International Fund. If you have any questions in connection with this filing, please call me at 612.340.6328. Very truly yours, James K. Moeller