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      EDGAR CORRESPONDENCE

      November 20, 2023

      U.S. Securities and Exchange Commission

        Division of Investment Management – Disclosure Review and Accounting Office

      100 F Street NE

        Washington DC 20549

      Attention: Ryan Sutcliffe

              Re:

              Davis New York Venture Fund, Inc. (40 Act File No.: 811-01701)

      Dear Mr. Sutcliffe:

      This letter is in response to comments you provided on November 9, 2023 and November 16, 2023, with respect to the 485(a) filing of
        Davis Research Fund, a series of Davis New York Venture Fund, Inc., as identified above. SEC comments are in bold. Registrant’s responses immediately follow.

                1.

                We request that you respond to these comments no later than five business days before
                  the filing is scheduled to become effective automatically. If this is not possible, we request that you file an amendment under Rule 485(b) delaying effectiveness as needed until Staff comments result.

      We confirm that we will respond no later than five business days before the filing is scheduled to become effective automatically.

                2.

                Please fill in all blanks, brackets, and otherwise missing information sufficiently
                  in advance of effectiveness for review.

      We confirm that all blanks, brackets, and otherwise missing information will be filled in in advance of effectiveness for review.

                3.

                Please bold the fee and expense paragraph, the example paragraph, the portfolio
                  turnover paragraph, and the financial highlights paragraph under Form N-1A. With regards to expenses, please provide fees and expenses and the example sufficiently in advance of effectiveness for review.

      Please find the changes below, as well as the fees and expenses and the example.

      Fees and Expenses of the Fund

      These tables describe the fees and expenses that you may pay if you buy, hold, and sell shares of
        the Fund. You may pay other fees, such as brokerage commissions and other fees to financial intermediaries, which are not reflected in the tables and examples below. You may qualify for sales charge discounts with respect to Class A shares if you
        and your family invest, or agree to invest in the future, at least $100,000 in Davis Funds. More information about these and other discounts is available from your financial intermediary and in “How to Choose a Share Class (Class A Shares)” on page 16 of the Fund’s prospectus and “Selecting
          the Appropriate Class of Shares” on page 32 of the Fund’s statement of additional information.

              Shareholder Fees*

              (fees paid directly from your investment)

              Class A shares

              Maximum Sales Charge (Load) Imposed on Purchases

              (as a percentage of offering price)

              4.75%

              Maximum Deferred Sales Charge (Load)

              (as a percentage of the lesser of the net asset value of the shares redeemed or the total cost of such shares)

              None

              Redemption Fee

              (as a percentage of total redemption proceeds)

              None

            *

              Shareholder fees do not apply to current and former directors, officers and employees of the Fund or its investment adviser and sub-adviser, as such investors are all
                eligible for a front-end sales charge waiver.

              Annual Fund Operating Expenses

              (expenses that you pay each year as a percentage of the value of your investment)

              Class A shares

              Management Fees

              0.55%

              Distribution and/or Service (12b-1) Fees

              0.00%

              Other Expenses

              0.15%

              Total Annual Operating Expenses

              0.70%

      …

      Example.
        This Example is intended to help you compare the cost of investing in the Fund with the cost of investing in other mutual funds. The Example assumes that you invest $10,000 in the Fund for the time periods indicated and then redeem all of your
        shares at the end of those periods. The Example also assumes that your investment has a 5% return each year and that the Fund’s operating expenses remain the same. Although your actual costs may be higher or lower, based on these assumptions, your
        costs would be:

              1 Year

              3 Years

              5 Years

              10 Years

              Class A shares

              $543

              $688

              $846

              $1,304

      …

      Portfolio Turnover

      The Fund pays transaction costs, such as commissions, when it buys and sells securities (or
        “turns over” its portfolio). A higher portfolio turnover rate may indicate higher transaction costs and may result in higher taxes when Fund shares are held in a taxable account. These costs, which are not reflected in annual fund operating
        expenses or in the example, affect the Fund’s performance. During the most recent fiscal year, the Fund’s portfolio turnover rate was 8% of the average value of its portfolio.

      …

      Financial Highlights

      The financial highlights table is intended to help you understand the Fund’s financial performance for the past 5
        years ended July 31, 2023. Certain information reflects financial results for a single Fund share. The total returns in the table represent the rate that an investor would have earned (or lost) on an investment in the Fund (assuming reinvestment of
        all dividends and distributions).

      This information has been audited by KPMG LLP, whose report, along with the Fund’s financial statements, are
        included in the annual report, which is available upon request.

                4.

                Please consider whether increased tax expenses should be included in shareholder
                  concentration risk.

      We have modified “Shareholder Concentration Risk” as follows:

      Shareholder
          Concentration Risk. From time to time, a relatively large percentage (over 20%) of the Fund’s shares may be held by related
        shareholders. A large redemption by one or more of such shareholders may reduce the Fund’s liquidity, may increase the Fund’s transactions and transaction costs, may result in substantial capital gains distributions for shareholders, and may
        increase the Fund’s ongoing operating expenses, which could negatively impact the remaining shareholders of the Fund.

                5.

                Please consider disclosure related to the Israel-Hamas war and the resulting elevated
                  risk of terrorism in the United States.

      We have modified “Stock Market Risk” as follows:

      Stock Market
          Risk. Stock markets tend to move in cycles, with periods of rising prices and periods of falling prices, including the possibility of sharp declines. As an example, U.S. and international markets have experienced volatility in recent
        months and years due to a number of economic, political and global macro factors including the impact of the coronavirus (COVID-19) as a global pandemic, uncertainties regarding interest rates, rising inflation, trade tensions and the threat of
        tariffs imposed by the U.S. and other countries. While COVID-19 is no longer a global pandemic as of 2023, the recovery from COVID-19 may last for a prolonged period of time. In addition, as a result of continuing political tensions and armed
        conflicts, including the war between Ukraine and Russia, the U.S. and the European Union imposed sanctions on certain Russian individuals and companies, including certain financial institutions, and have limited certain exports and imports to and
        from Russia. The war may continue to contribute market volatility. The Israel-Hamas war may lead to overall economic uncertainty and negative impacts on the global economy and major financial markets. These developments as well as other events
        could result in further market volatility and negatively affect financial asset prices, the liquidity of certain securities and the normal operations of securities exchanges and other markets. Continuing market volatility as a result of recent
        market conditions or other events may have an adverse effect on the performance of the Fund.

                6.

                Please confirm that the fund is a limited derivatives user under 18f-4 and limits
                  derivative exposure to 10% of assets.

      We confirm that the Fund is prohibited from investing in derivatives, excluding certain currency and interest rate hedging
        transactions. This restriction is not fundamental and may be changed by the Fund without a shareholder vote. If the Fund does determine to invest in derivatives in the future, it will comply with Rule 18f-4 under the 1940 Act.

                7.

                Under item 17(a), please make clear the principal occupation for the last five years
                  for Ms. Cohen and Ms. McLoughry.

      We have modified these sections as follows:

      Lisa J. Cohen
          (born 04/25/89, Davis Funds officer since 2021). Vice President and Secretary of the Davis Funds (consisting of 13 portfolios), Selected Funds (consisting of two portfolios), Clipper Funds Trust (consisting of one portfolio), and Davis
        Fundamental ETF Trust (consisting of four portfolios); Vice President, Chief Legal Officer, and Secretary, Davis Selected Advisers, L.P., and also serves as an executive officer of certain companies affiliated with the Adviser. Prior to assuming
        these positions, Ms. Cohen worked for Honeywell International, Inc. (01/2020-06/2021) and as an attorney at Davis Selected Advisers, L.P. (12/2015-01/2020).

      Michaela
          McLoughry (born 03/21/81, Davis Funds officer since 2023). Vice President and Chief Compliance Officer of the Davis Funds (consisting of 13 portfolios), Selected Funds (consisting of two portfolios), Clipper Funds Trust (consisting of one
        portfolio), and Davis Fundamental ETF Trust (consisting of four portfolios); Vice President and Chief Compliance Officer, Davis Selected Advisers, L.P., and also serves as an executive officer of certain companies affiliated with the Adviser. Prior
        to assuming these positions, Ms. McLoughry spent close to 18 years in the Fund Accounting department at Davis Selected Advisers, L.P.

                8.

                Due to the deferred sales charge, please provide an additional example reflecting
                  redemptions that would activate such charge.

      Because the Fund is only available to current and former directors, officers, and employees of the Fund or its investment adviser and
        sub-adviser, and such investors are all eligible for a front-end sales charge waiver, such deferred sales charges would not be assessed. Therefore, as shown in the response to the third comment above, the deferred sales charge has been changed to
        “None” and the footnote below the chart has been revised as indicated.

                9.

                Registrant should consider an explanatory footnote regarding purchases of $1 million
                  or more and the 0.50% fee.

      We have considered such explanatory footnote, and have determined that it is not necessary to add.

      Please call the undersigned at (520) 434-3793 with any comments or questions.

      Respectfully,

      /s/ Lisa Cohen

           Lisa Cohen

           Vice President and Secretary

      DAVIS RESEARCH FUND

      PROSPECTUS

      A Portfolio of Davis New York Venture Fund, Inc.

      November 29, 2023

      Class A Shares (DRFAX)

      The Securities and Exchange Commission has not approved or disapproved these securities or passed upon the adequacy of this prospectus. Any representation to
        the contrary is a criminal offense.

      LOGO

      OVER 50 YEARS OF RELIABLE INVESTINGSM

              Contents

              Davis Research Fund Summary

              3

              Additional Information About Investment Objectives, Principal Strategies and Principal Risks

              6

              Additional Information About Expenses, Fees and Performance

              8

              Non-Principal Investment Strategies and Risks

              9

              Management and Organization

              10

              Shareholder Information

              11

              How Your Shares Are Valued

              11

              Portfolio Holdings

              12

              How Davis Funds Pay Earnings

              12

              Federal Income Taxes

              13

              Fees and Expenses of the Fund

              14

              Fees Paid to Dealers and Other Financial Intermediaries

              14

              How to Choose a Share Class (Class A Shares)

              16

              How to Open an Account

              19

              Anti-Money Laundering Compliance

              19

              Retirement Plan Accounts

              20

              How to Buy, Sell and Exchange Shares

              20

              Buying More Shares

              21

              Selling Shares

              22

              Exchanging Shares

              24

              Frequent Purchases and Redemptions of Fund Shares

              24

              Telephone Transactions

              25

              Internet Transactions

              25

              Financial Highlights

              26

              Obtaining Additional Information

              28

        Class A shares of Davis Research Fund have been registered with the Securities and Exchange Commission and, as of the date of this prospectus, in selected
          states where eligible investors are residents. Shares of Davis Research Fund currently are not available for public sale in any other state or jurisdiction. Currently, only current and former directors, officers and employees of the Fund or its
          investment adviser and sub-adviser (and the investment adviser itself and affiliated companies) are eligible to purchase Fund shares. The Adviser reserves the right to reject any offer to purchase shares.

      This prospectus contains important information. Please read it carefully before investing and keep it for future reference.

      No financial adviser, dealer, salesperson or any other person has been authorized to give any information or to make any representations, other than those
        contained in this prospectus, in connection with the offer contained in this prospectus and, if given or made, such other information or representations must not be relied on as having been authorized by the Fund, the Fund’s investment adviser or
        the Fund’s distributor.

        This prospectus does not constitute an offer by the Fund or by the Fund’s distributor to sell or a solicitation of an offer to buy any of the securities offered
          hereby in any jurisdiction to any person to whom it is unlawful for the Fund to make such an offer.

      Davis Research Fund Summary

      Investment Objective

      The Fund seeks long-term growth of capital.

      Fees and Expenses of the Fund

      These tables describe the fees and expenses that you may pay if you buy, hold, and sell shares of the Fund. You may pay other fees, such as
        brokerage commissions and other fees to financial intermediaries, which are not reflected in the tables and examples below. You may qualify for sales charge discounts with respect to Class A shares if you and your family invest, or agree to invest
        in the future, at least $100,