1775 I Street, N.W.
[LOGO OF Dechert]                                 Washington, DC 20006-2401
             LLP                                  +1  202  261  3300  Main
                                                  +1  202  261  3333  Fax
                                                  www.dechert.com

                                                  ------------------------------

                                                  JULIEN BOURGEOIS

                                                  julien.bourgeois@dechert.com
                                                  +1  202  261  3451  Direct
                                                  +1  202  261  3151  Fax

September 23, 2011

VIA EDGAR

Filing Desk
Securities and Exchange Commission
Office of Filings and Information Services
Branch of Registrations and Examinations
Mail Stop 0-25
100 F Street, NE
Washington, D.C. 20549

Re:     Security Equity Fund (File No. 811-01136)
        Security Large Cap Value Fund (File No. 811-00487)
        Security Mid Cap Growth Fund (File No. 811-01316)
        Security Income Fund (File No. 811-02120)
        SBL Fund (File No. 811-02753)
        (each a "Company," and collectively, the "Companies")

Ladies and Gentlemen:

Pursuant to Rule 14a-6 under the Securities Exchange Act of 1934, attached for
filing via the EDGAR system is a preliminary proxy statement, form of proxy, and
other soliciting material ("Proxy Materials") for a Joint Special Meeting of
Shareholders ("Meeting") of the Companies to be held on November 22, 2011.

The Meeting is being held for the purpose of asking shareholders: (i) to approve
new Investment Management Agreements between Security Investors, LLC and the
Companies, on behalf of each series of the Companies in connection with a
corporate transaction that may result in a change in control; (ii) to elect
nominees to the Boards of Directors of the Companies; (iii) with respect to SBL
Fund-Series N (Managed Asset Allocation Series), to approve a change to the
fundamental investment policy on diversification of investments.

-------------------------
US Austin Boston Charlotte Hartford Los Angeles New York Orange County
Philadelphia Princeton San Francisco Silicon Valley Washington DC EUROPE
Brussels Dublin London Luxembourg Moscow Munich Paris ASIA Beijing Hong Kong


[LOGO OF Dechert]                                      September 23, 2011
             LLP                                       Page 2

No fee is required in connection with this filing. Should you have any
questions or comments, please contact me at 202.261.3451.

Sincerely,

/s/ Julien Bourgeois
--------------------

Julien Bourgeois
Attachments