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AB FUNDS

501 Commerce Street

Nashville, TN 37203

March 20, 2023

VIA EDGAR CORRESPONDENCE

Division of Investment Management

Disclosure Review and Accounting Office

U.S. Securities and Exchange Commission

100 F Street, NE

Washington, DC 20549

Attention: Melissa McDonough

Re: In the matter of the SEC Filings set forth in Appendix B hereto

Dear Ms. McDonough:

Attached as Appendix A are responses to the comments made during your phone
conversation with Phyllis Clarke and other representatives of AllianceBernstein L.P. (the "Adviser" or "we") on February
16, 2023.

If you have any questions regarding our response, please do not hesitate
to call me at 914.259.7740.

Sincerely,

/s/ Joseph Mantineo

Joseph Mantineo

Treasurer and Chief Financial

Officer of each Fund

 cc: Michael Reyes, Senior Vice President of the Funds

Kyle DiGangi, AllianceBernstein L.P.

Nancy Hay, AllianceBernstein L.P.

Stephen Laffey, AllianceBernstein L.P.

Vince Noto, AllianceBernstein L.P

Jennifer Friedland, AllianceBernstein L.P

Steve Woetzel, AllianceBernstein L.P.

Phyllis Clarke, AllianceBernstein L.P.

Appendix A

Comment #1:

All Funds in Complex (Form N-CSR)

Regarding N-CSR Item 11(b), Controls and Procedures: the Funds refer to
“the period”, but the Form calls for the Funds to state, “during the period covered by this report”. Please confirm
nothing has changed during the period covered by the reports and adopt the new language going forward.

Response #1:

The Adviser confirms there are no changes during the period covered by
these reports and will revise the language accordingly in future N-CSR filings.

Comment #2:

All Funds in Complex (Form N-CSR)

Regarding N-CSR 30a-2(a) Certification Exhibits, paragraph 4(d): the Funds,
refer to stale language for the quarter and should address period covered by the report. Need amended N-CSR certification exhibits to
address period that is covered in the report.

Response #2:

The Adviser has amended the Form N-CSR filings for all 2022 Annual Reports.

Comment #3:

All Funds in Complex (Form N-CSR)

Regarding N-CSR Item 4(e)(2), Principal Accountant Fees and Services: the
Form requires a percentage of services approved by the audit committee pursuant to Regulation S-X Rule 2-01 (c)(7)(i)(C) to be disclosed
for paragraphs b-d instead of a-c.

Response #3:

The Adviser will revise the language accordingly in future Form N-CSR filings.

Comment #4:

AB Select US Equity Long/Short Portfolio

The Fund has over 51% investment in AB Government Money Market Portfolio,
prior year was around 30% and Semi-Annual around 33%. Current objective states long-term growth of capital. Please describe why such a
significant amount is not disclosed within the prospectus investment strategies and risk?

Response #4:

The Adviser believes that the prospectus includes appropriate disclosure
about the potential for the Fund to hold a significant level of cash and cash equivalents, like the AB Government Money Market Portfolio.
The Fund’s 80% investment policy specifically includes “U.S. cash equivalents,” and disclosure elsewhere under “Principal
Strategies” refers to the Fund “holding a material level of cash and/or cash equivalents.”

Comment #5:

AB Select US Equity Portfolio, AB Select US Equity Long/Short Portfolio,
AB Tax-Managed Wealth Appreciation Strategy & AB Tax-Managed All Market Income Portfolio

Within the financial highlights a footnote states, “Includes the
impact of proceeds received, and credited to the Fund resulted from class action settlements”. Please describe where the class action
settlements are in the financials.

Response #5:

The Adviser confirms class action settlements are disclosed on the Statement
of Operations within Net realized gain (loss) on Investment transactions, pursuant to FASB ASC 946-320-35-21.

Comment #6:

AB All Market Total Return Portfolio & AB Tax-Managed All Market
Income Portfolio

Please advise whether any unaffiliated investment companies in which these
Funds invest have made a distribution of realized gains, and if so, state separately (Reg SX 6.07.7b).

Response #6:

The Adviser confirms no distributions of realized gains were made from
unaffiliated investment company investments.

Comment #7:

AB All Market Total Return Portfolio & AB Sustainable Thematic Balanced
Portfolio

It was noted the fee table in the prospectus does not match the financial
highlights, please reconcile the financial highlights to the fee table in the prospectus.

Response #7:

For Sustainable Thematic Balanced, the prospectus fee table restates the
advisory fee to reflect the reduction in the Fund’s effective contractual advisory fee rate from .55% to .50%, effective December
1, 2021. The fee table also restates the fee waiver/expense reimbursements and net expenses to reflect the imposition of expenses caps,
effective December 1, 2021 (limiting total expenses annually to 1.00%, 1.75%, .75%, 1.25%, 1.00%, .75%, and .75% for Class A, Class C,
Advisor Class, Class R, Class K, Class I and Class Z shares, respectively).

The financial highlights reflect the blended advisory fee rate and total
expense ratio levels for the fiscal year. The fee table does not reflect the acquired fund fees, addressed in the financial highlights
footnotes, as a separate line item since acquired fund fees did not exceed .01% in the wake of investment strategy changes implemented
effective December 1, 2021.

For All Market Total Return Portfolio, the prospectus fee table reflects
acquired fund fees of .02% and a waiver in connection with such acquired fund fees of .01%. The financial highlights do not reflect acquired
fund fees directly in the financial highlights table, but do address acquired fund fees and related waivers in the table footnotes.

Comment #8:

AB Sustainable Thematic Balanced Portfolio & AB International Strategic
Core Portfolio

Both Funds have less than 5 years in the financial highlights, but the
opinion addresses 5 years. Please refile the financials with an updated opinion.

Response #8:

The Adviser believes the current opinion related to the respective Fund
is appropriate. All classes within both Funds present a full 5 years, except for Class Z, which has been in existence for less than 5
years.

Comment #9:

Sanford C. Bernstein Fund II, Inc (Intermediate Duration Institutional
Portfolio)

Please explain if active and frequent trading is part of the investment
strategy, and if so, why is the portfolio turnover risk not included within the prospectus.

Response #9:

Active and frequent trading is not part of the Fund’s investment
strategy which is why portfolio turnover risk is not mentioned as a principal risk in the prospectus. In this period, the utilization
of government-agency-related To Be Announced mortgage positions contributed to the Fund’s turnover rate. The Adviser monitors each
Fund’s turnover rate and if it exceeds 200%, will add portfolio turnover risk to the prospectus. Further disclosure regarding portfolio
turnover is included in the prospectus in the “Additional Investment Information” section.

Comment #10:

Sanford C. Bernstein Fund, Inc (California Municipal Portfolio, Diversified
Municipal Portfolio, New York Municipal Portfolio, Short Duration Diversified Municipal Portfolio) & Sanford C. Bernstein Fund II,
Inc (Intermediate Duration Institutional Portfolio)

Please explain why there were no proxy voting records on the website.

Response #10:

The Adviser confirms there were no proxies voted for the fixed-income Funds.

Comment #11a:

Sanford C. Bernstein Fund, Inc (Emerging Markets Portfolio)

Line graph does not assume a $10K investment as the graph shows a $25K
investment. Please explain why this does not show a $10K investment.

Response #11a:

The Adviser will use an investment of $10K in the line graphs in the
Emerging Markets Portfolio’s shareholder reports going forward.

Comment #11b:

Sanford C. Bernstein Fund II, Inc (Intermediate Duration Institutional
Portfolio)

Line graph assumes a $25K investment. Please explain why this does not
align to the prospectus, which shows a $3MM minimum investment.

Response #11b:

The Adviser will use the minimum investment of $3MM in the line graphs
in the fund’s shareholder reports going forward.

Comment #12:

Sanford C. Bernstein Fund, Inc & Bernstein Fund, Inc (Form N-CEN)

Attachment for the N-CEN internal control letter for the Sanford C. Bernstein
Fund, Inc. filing also includes letter for Bernstein Fund, Inc. (and includes the Sanford C. Bernstein Fund, Inc letter for the latter
Fund filing). Please amend the Form N-CEN to only include the proper control letter for the specific registrant.

Response #12:

The Adviser has amended the Form N-CEN filings Sanford C. Bernstein Fund,
Inc and Bernstein Fund, Inc.

Appendix B

    1940 Act File Number
    Series Name
    Registrant Name
    Fiscal Year-End Reviewed

    811-02383
    AB Limited Duration High Income Portfolio
    AB BOND FUND, INC.
    9/30/2022

    811-01716
    AB Small Cap Growth Portfolio
    AB CAP FUND, INC.
    7/31/2022

    811-01716
    AB Select US Equity Portfolio
    AB CAP FUND, INC.
    6/30/2022

    811-01716
    AB Select US Long/Short Portfolio
    AB CAP FUND, INC.
    6/30/2022

    811-01716
    AB Concentrated Growth Fund
    AB CAP FUND, INC.
    6/30/2022

    811-01716
    AB Concentrated International Growth Portfolio
    AB CAP FUND, INC.
    6/30/2022

    811-01716
    AB Global Core Equity Portfolio
    AB CAP FUND, INC.
    6/30/2022

    811-01716
    AB International Strategic Core Portfolio
    AB CAP FUND, INC.
    6/30/2022

    811-01716
    AB FlexFee Large Cap Growth Portfolio
    AB CAP FUND, INC.
    6/30/2022

    811-01716
    AB Sustainable US Thematic Portfolio
    AB CAP FUND, INC.
    6/30/2022

    811-05088
    AB Sustainable Thematic Balanced Portfolio
    AB PORTFOLIOS
    8/31/2022

    811-05088
    AB All Market Total Return Portfolio
    AB PORTFOLIOS
    8/31/2022

    811-05088
    AB Tax-Managed All Market Income Portfolio
    AB PORTFOLIOS
    8/31/2022

    811-05088
    AB Wealth Appreciation Strategy
    AB PORTFOLIOS
    8/31/2022

    811-05088
    AB Tax-Managed Wealth Appreciation Strategy
    AB PORTFOLIOS
    8/31/2022

    811-07732
    ALLIANCEBERNSTEIN GLOBAL HIGH INCOME FUND INC
    ALLIANCEBERNSTEIN GLOBAL HIGH INCOME FUND INC
    3/31/2022

    811-21034
    Bernstein Intermediate Duration Institutional Portfolio
    BERNSTEIN SANFORD C FUND II INC
    9/30/2022

    811-05555
    California Municipal Portfolio
    BERNSTEIN SANFORD C FUND INC
    9/30/2022

    811-05555
    Short Duration Plus Portfolio
    BERNSTEIN SANFORD C FUND INC
    9/30/2022

    811-05555
    Diversified Municipal Portfolio
    BERNSTEIN SANFORD C FUND INC
    9/30/2022

    811-05555
    Emerging Markets Portfolio
    BERNSTEIN SANFORD C FUND INC
    9/30/2022

    811-05555
    Intermediate Duration Portfolio
    BERNSTEIN SANFORD C FUND INC
    9/30/2022

    811-05555
    New York Municipal Portfolio
    BERNSTEIN SANFORD C FUND INC
    9/30/2022

    811-05555
    Short Duration Diversified Municipal Portfolio
    BERNSTEIN SANFORD C FUND INC
    9/30/2022

    811-05555
    Overlay A Portfolio
    BERNSTEIN SANFORD C FUND INC
    9/30/2022

    811-05555
    Tax-Aware Overlay A Portfolio
    BERNSTEIN SANFORD C FUND INC
    9/30/2022

    811-05555
    Overlay B Portfolio
    BERNSTEIN SANFORD C FUND INC
    9/30/2022

    811-05555
    Tax-Aware Overlay B Portfolio
    BERNSTEIN SANFORD C FUND INC
    9/30/2022

    811-05555
    Tax-Aware Overlay C Portfolio
    BERNSTEIN SANFORD C FUND INC
    9/30/2022

    811-05555
    Tax-Aware Overlay N Portfolio
    BERNSTEIN SANFORD C FUND INC
    9/30/2022