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CORRESP

 THE ALGER FUNDS

100 Pearl Street, 27th Floor

New York, New York 10004

 June 2,
2025

 VIA EDGAR

 Securities and Exchange Commission

 100 F Street, N.E.

 Washington, D.C. 20549

Attn: Anu Dubey

Re:
 Alger International Small Cap Fund, a series of The Alger Funds

(File Nos.: 33-4959, 811-1355)

Dear Ms. Dubey:

 On behalf of Alger
International Small Cap Fund (the “Fund”), a series of The Alger Funds (the “Registrant”), this letter responds to the comments provided by the staff of the Division of Investment Management (the “Staff”) of the
Securities and Exchange Commission (the “Commission”) to the undersigned and Mia G. Pillinger by telephone on May 21, 2025, regarding Post-Effective Amendment No. 152 to the Registrant’s Registration Statement on Form N-1A under the Securities Act of 1933, as amended (the “1933 Act”), and the Investment Company Act of 1940, as amended (the “1940 Act”), which was filed with the Commission on April 15, 2025
(the “Registration Statement”) in order to launch the Fund.

 The Staff’s comments have been restated below in italicized
text. The Registrant’s responses to the Staff’s comments are set out immediately under the restated comment. The Registrant plans to file an amendment to the Registration Statement (the “Amendment”) on or about June 30,
2025, in order to (i) reflect changes made in response to the Staff’s comments, (ii) file certain exhibits, and (iii) make certain other non-material revisions. Unless otherwise indicated,
defined terms used herein have the meanings set forth in the Registration Statement. Where comments were provided to the prospectus for one share class of the Fund, the Registrant has made conforming changes to the Fund’s other share class
prospectus.

 Prospectus Summary—Fund Fees and Expenses

Comment No. 1:

Please provide for the Staff’s review in this response letter a completed fee table for each of the Fund’s two share classes.

Response No. 1:

Please refer to Attachment A to this response letter, which includes completed fee tables for Class A and Class Z shares of the Fund.

Comment No. 2:

In footnote *** to each share class’s fee table, the Staff notes that the waiver agreement does not exclude advisory fees. Please explain how waiving advisory fees does not constitute impermissible cross-subsidization of the
advisory fee under Rule 18f-3. Please refer to the Staff’s guidance in the bulletin entitled “Differential Advisory Fee Waivers” (dated Feb. 2,
2023).

 June 2, 2025

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Response No. 2:

The Registrant notes, as disclosed in footnote *** to each share class’s fee table, that the contractual agreement is to limit “other expenses and any other applicable share class-specific expenses,” rather than
limiting each share class’s total expense ratio. The Registrant has specifically structured and intended for this waiver agreement, and the related waiver structure, to comply with Rule 18f-3 and to avoid
impermissible cross-subsidization of the advisory fee, by limiting the scope of the agreement only to “Other Expenses” and “share class-specific expenses” (i.e., Rule 12b-1 Fees).
The Registrant therefore believes that the waiver agreement expressly complies with the requirements of Rule 18f-3 and the Staff’s guidance cited above.

Comment No. 3:

Please confirm that the waiver agreement referenced in footnote *** to each share class’s fee table will be filed as an exhibit to the Fund’s Registration Statement.

Response No. 3:

The Registrant confirms that the waiver agreement will be filed as an exhibit to the Amendment.

Prospectus Summary—Principal Investment Strategy

Comment No. 4:

The third paragraph of the Fund’s principal investment strategy states that the Fund invests “primarily” in equity securities of international small cap companies. Please disclose what “primarily” means
with specificity (i.e., disclose a specific amount).

Response No. 4:

The Registrant respectfully notes that the term “international” describes the Fund’s approach to constructing a portfolio, but does not communicate the composition of the Fund’s portfolio with any particularity,
and is, therefore, not subject to the requirements of Rule 35d-1 under the 1940 Act (the “Names Rule”) (see 2023 Names Rule adopting release (Investment Company Names, Release No. 33-98438 (Sep. 20, 2023)) at pages 43-44). The Registrant does not generally have a practice of defining what “primarily” translates to as a percentage of
assets for terms not subject to the Names Rule. The Registrant intends to follow this practice with the Fund’s disclosure and has therefore not added language defining “primarily” in percentage terms.

Comment No. 5:

One of the ways that the Fund defines small cap companies is companies that, at the time of purchase of the securities, have a total market capitalization in the range of companies included in the MSCI World ex-USA Small Cap Index. The Staff notes that as of March 31, 2025, the market capitalization of companies in the MSCI World ex-USA Small Cap Index ranged from
$128 million to $11.2 billion. Please explain supplementally to the Staff why the Fund considers a company with a market capitalization at the top of this range to be a small cap company for an international fund. Is it consistent with
industry indices, classifications used by rating organizations, or definitions used in financial publications? See Question 6 of the Staff’s 2001 Frequently Asked Questions about Rule 35d-1 (the
“2001 Names Rule FAQs”).

Response No. 5:

The Registrant believes that the Fund’s current definition of small cap companies as those companies that, at the time of purchase of the securities, have a total market capitalization in the range of (i) companies
included in the MSCI World ex-USA Small Cap Index, or (ii) $500 million to $8 billion, is appropriate.

 June 2, 2025

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The Registrant respectfully notes that in connection with the 2023 adoption of amendments to the Names Rule, in January 2025 the Staff withdrew Question 6 of the 2001 Names Rule FAQs. However, under the Names Rule, as recently
amended, funds have the flexibility to define the terms used in their names, provided that the meanings of such terms are consistent with plain English or established industry use. The Registrant believes that the use of the MSCI World ex-USA Small Cap Index and a market cap range of up to $8 billion, as contemplated for the Fund, meets these requirements.

The Registrant believes that its use of the MSCI World ex-USA Small Cap Index for this purpose is appropriate. As set forth in the factsheet for the MSCI World
ex-USA Small Cap Index, the index “captures small cap representation across 22 of 23 Developed Markets (DM) countries (excluding the United States)” and “covers approximately 14% of the free
float-adjusted market capitalization in each country.” This means that the index includes the smaller companies comprising approximately 14% of the total value of public equities in the DM countries (which, for purposes of the index, include
Australia, Austria, Belgium, Canada, Denmark, Finland, France, Germany, Hong Kong, Ireland, Israel, Italy, Japan, Netherlands, New Zealand, Norway, Portugal, Singapore, Spain, Sweden, Switzerland and the UK).

MSCI’s non-US indices are the most widely used and widely recognized indices for international small cap companies in the industry, and many international small cap funds use these
indices for purposes of defining small cap companies and/or as a benchmark index. While Morningstar does not have an international small cap category, based on the Registrant’s analysis of funds across Morningstar’s Foreign Small/Mid
market segment (including blend, growth, and value), of which the Fund would be a part of and of which approximately 50% of funds are small cap only funds, the MSCI World ex-USA Small Cap Index and MSCI’s
other international small cap indices (the MSCI EAFE Small Cap Index and MSCI ACWI ex USA Small Cap Index) represent 38% of listed prospectus benchmarks. As of April 30, 2025, constituents in the MSCI EAFE Small Cap Index ranged between
$105 million and $10.9 billion and constituents in the MSCI ACWI ex USA Small Cap Index ranged between $63 million and $12 billion.

Based on the widespread use and recognition of MSCI’s international small cap indices, the Registrant believes that its definition of small cap companies by reference to this index is consistent with investors’
expectations and established industry use. Moreover, the Registrant has clearly disclosed its definition of small cap and, as noted in response to Comment No. 6 below, will disclose the market capitalization range of the index as of a recent
date.

Additionally, the Registrant believes it has become established industry practice to define market capitalization based on industry benchmarks. The Registrant believes that companies with market capitalizations in the range of
$500 million to $8 billion are appropriately considered small cap for an international fund based on industry benchmarks that track international small cap companies. For example, in addition to the MSCI benchmarks referenced above, as of
April 30, 2025, (i) the FTSE Global Small Cap ex US Index and the FTSE Developed Small Cap ex US Index (market-capitalization weighted indices representing the performance of small cap stocks in developed and emerging markets or developed only
markets, excluding the US) ranged in market capitalization from $0 to $22 billion; and (ii) the S&P Global Ex US Small Cap Index and the S&P Developed

 June 2, 2025

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Ex-U.S. SmallCap Index (which seek to measure the stocks representing the lowest 15% of float-adjusted market cap in either developed and emerging countries or in developed only countries,
excluding the US) ranged in market capitalization from $6.15 million to $18.9 billion. $500 million to $8 billion are well within the range of these established industry benchmark indices.

Lastly, as markets change over time, the small capitalization range in the international stock market likewise changes. Accordingly, the Registrant believes it is appropriate to use both an index and a static market cap range as the
basis for its definition of small cap companies, which will permit Redwood to manage the Fund to reflect fluctuations in the markets over time. Further, the Fund’s definition of small cap companies to include a static market cap range in
addition to an index is designed to smooth out volatile swings in the MSCI World ex-USA Small Cap Index market capitalization range at the time of quarterly rebalances, during which the upper boundary of the
range can drop considerably overnight.

For these reasons, the Registrant believes that its definition of small cap is appropriate and consistent with regulatory requirements.

Comment No. 6:

Please disclose the market capitalization range of the MSCI World ex-USA Small Cap Index as of a recent date.

Response No. 6:

The Registrant will make the requested change in the Amendment.

Comment No. 7:

One of the ways that the Fund defines small cap companies is companies that, at the time of purchase of the securities, have a total market capitalization in the range of $500 million to $8 billion. Please explain
supplementally to the Staff why the Fund considers a company with a market capitalization of $8 billion to be a small cap company for an international fund. Is it consistent with industry indices, classifications used by rating organizations,
or definitions used in financial publications? See Question 6 of the 2001 Names Rule FAQs.

Response No. 7:

The Registrant believes its definition of small cap companies (including companies with a market capitalization of up to $8 billion) meets the requirements of the Names Rule. Please refer to the response to Comment No. 5
above.

Comment No. 8:

The third paragraph of the Fund’s principal investment strategy states that the Fund generally holds approximately 50 holdings. Please add corresponding risk disclosure regarding holding a limited number of issuers or
explain to the Staff why such disclosure is not necessary.

Response No. 8:

The Registrant will add the requested risk disclosure in the Amendment.

Prospectus Summary—Management

Comment No. 9:

Please move the paragraph discussing co-management of the Fund out of the summary prospectus. See General Instruction C.3(b) to Form
N-1A.

Response No. 9:

The Registrant will make the requested change in the Amendment and move the disclosure regarding co-management of the Fund to the Item 10
disclosure.

 June 2, 2025

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Prospectus Summary—Shareholder Information

Comment No. 10:

The first sentence in this section of the summary prospectus states: “Minimum Investments: the following minimums apply to an account in the Fund, whether invested in Class A Shares.” This sentence appears to be
incomplete. Please revise.

Response No. 10:

The Registrant will make the requested change in the Amendment and revise the sentence to state: “Minimum Investments: the following minimums apply to an account in the Fund.”

Prospectus—Investment Objectives, Principal Investment Strategies and Related Risks—ESG Integration

Comment No. 11:

Please disclose what ESG factors Redwood looks at when integrating ESG analysis into its investment process.

Response No. 11:

While the Redwood investment team integrates ESG analysis into both the quantitative and qualitative components of their investment process, Redwood does not prioritize any one ESG factor over another and generally considers
environmental, social, or governance issues that Redwood believes may materially impact the long-term performance of a company. The Registrant will include in the Amendment the revised disclosure set forth below to clarify this point.

 Although the Fund does not seek to implement a specific environmental, social and governance (“ESG”), impact
or sustainability strategy unless otherwise disclosed, the Redwood investment team integrates ESG analysis into both the quantitative and qualitative components of their investment process through the use of both third-party ESG specific information
and its own proprietary research. The foundation of the Redwood investment process is bottom-up, fundamental research that seeks engagement with management about the most relevant and critical ESG variables to
help identify opportunities and avoid risk. Redwood complements this engagement with research provided by third-party resources. Redwood does not prioritize any one ESG factor over another and generally considers environmental, social, or
governance issues that Redwood believes may materially impact the long-term performance of a company.

Comment No. 12:

Please explain supplementally to the Staff why there is no corresponding principal risk disclosure included regarding integrating ESG factors. Alternatively, please consider adding principal risk disclosure regarding integration
of ESG factors.

Response No. 12:

As disclosed in the Registration Statement, the Fund does not seek to implement a specific ESG, impact, or sustainability strategy and therefore does not consider ESG investing to be a principal investment strategy of the Fund. The
disclosure regarding integration of ESG is related to Redwood’s overall investment process.

Because ESG investing is not a principal investment strategy of the Fund, the Registrant does not believe principal risk disclosure regarding integration of ESG factors are required under Form
N-1A. The Registrant respectfully notes that the third paragraph of the ESG Integration disclosure includes a brief discussion of the potential risks of ESG considerations. The Registrant believes this
disclosure is sufficient to address the risks regarding integration of ESG factors into Redwood’s investment process.

 June 2, 2025

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Prospectus—Shareholder Information—Purchasing and Redeeming Fund Shares

Comment No. 13:

The first par