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    Chicago

    New York

    Washington, DC

    London

    San Francisco

    Los Angeles

    Singapore

    Dallas

    Miami

    vedderprice.com

    November 2, 2023

    Renee M. Hardt

    Shareholder

    +1 312 609 7616

    rhardt@vedderprice.com

U.S. Securities and Exchange Commission

Division of Investment Management

100 F Street, N.E.

Washington, D.C. 20549

    Attn:
    Tony Burack

    Deborah O’Neal

    Re:
    The Oberweis Funds (the “Registrant”)

    Registration Statement on Form N-14

    File No. 333-274886

To the Commission:

On behalf of the Registrant, this letter is in response to the comments
provided telephonically by the staff of the U.S. Securities and Exchange Commission (the “Commission”) to Vedder Price P.C.
on October 30, 2023 and November 1, 2023 with respect to the Registrant’s Registration Statement on Form N-14 filed on October
6, 2023 (the “Registration Statement”) relating to the issuance of Institutional Class shares in connection with the proposed
reorganization of Oberweis International Opportunities Institutional Fund (the “Target Fund”), a series of the Registrant
into Oberweis International Opportunities Fund (the “Acquiring Fund”), a series of the Registrant (the “Reorganization”).
The Target Fund and the Acquiring Fund are each referred to herein as a “Fund” and collectively as the “Funds.”
Any capitalized terms used but not defined herein have the same meanings as given to them in the Registration Statement. Set forth below
are the staff’s comments and the Registrant’s responses.

Proxy Statement/Prospectus

Comment
(1)      In the second Q&A, the answer states that the Acquiring Fund will have the same fee structure as the Target Fund. Please
revise the disclosure since the Acquiring Fund’s total expenses will be higher than the Target Fund’s.

Response:           The
disclosure has been revised to state that the Acquiring Fund will have the same management fee and expense limitation as the Target Fund.

Comment
(2)      In the Q&A regarding expenses, please revise the disclosure to note that the total expenses of the Acquiring Fund will
be higher than the total expenses of the Target Fund.

 Response:           The disclosure has been revised to state that, although the total expenses of the Acquiring Fund will be higher than the total expenses of the Target Fund, the net expenses are expected to be the same.

222 North LaSalle Street | Chicago, Illinois 60601 | T +1 312 609 7500
| F +1 312 609 5005

Vedder Price P.C. is affiliated with Vedder Price LLP, which operates
in England and Wales, Vedder Price (CA), LLP, which operates in California, Vedder Price Pte. Ltd., which operates in Singapore, and Vedder
Price (FL) LLP, which operates in Florida.

U.S. Securities
and Exchange Commission

November 2, 2023

Page 2

Comment
(3)      In the Q&A regarding costs, please disclose the approximate amount of the costs of the reorganization. Please confirm
supplementally that OAM will not recoup any of such costs.

 Response:           The Registrant has added the requested disclosure. The Registrant confirms that OAM will not recoup the costs of the reorganization.

Comment
(4)      In the section “Summary – Background,” the disclosure states that the Acquiring Fund will have the same
fee structure as the Target Fund. Please revise the disclosure since the Acquiring Fund’s total expenses will be higher than the
Target Fund’s.

Response:           The
disclosure has been revised to state that the Acquiring Fund will have the same management fee and expense limitation as the Target
Fund.

Comment
(5)      In the section “The Board’s Approval of the Reorganization,” the first paragraph states that the Acquiring
Fund will have the same fee structure as the Target Fund. Please revise the disclosure since the Acquiring Fund’s total expenses
will be higher than the Target Fund’s. In addition, the first bullet point states that the Acquiring Fund will have the same expenses
as the Target Fund.; revise the disclosure since the Acquiring Fund’s total expenses will be higher than the Target Fund’s.

 Response:           The first paragraph has been revised to state that the Acquiring Fund will have the same management fee and expense limitation as the Target Fund. The first bullet point has been revised to state that, although the total expenses of the Acquiring Fund will be higher than the total expenses of the Target Fund, the net expenses are expected to be the same.

Comment
(6)       Please confirm that the Board understood that the total expenses of the Acquiring Fund would be higher (by three basis
points) than the total expenses of the Target Fund.

 Response:            In approving the Reorganization, the Board considered that, although the total expenses of the Acquiring Fund would be higher than the total expenses of the Target Fund, the net expenses of the Acquiring Fund would be the same as the net expenses of the Target Fund.

Accounting Comments

Comment
(7)      In the Q&A regarding expenses, the last sentence incorrectly states that total operating expenses of the Acquiring
Fund’s Institutional Class shares following the Reorganization are expected to be the same as the total and net operating expenses
of the Target Fund.

 Response:           Please see the response to Comment (2).

Comment
(8)      Please include hyperlinks for any documents incorporated by reference.

Response:           The
Registrant has included hyperlinks accordingly.

U.S. Securities
and Exchange Commission

November 2, 2023

Page 3

Comment
(9)      In footnote 2 to the fee table, the expense limitation is stated as 1.10%, while it is shown as 1.35% in the fee table.

 Response:          The footnote has been revised to state the expense limitation as 1.35%.

Comment
(10)    Please recalculate the numbers in the expense example so that they are consistent with the fee table and so that the expense
limitation is only reflected for the contractual period of the expense limitation agreement.

Response:           The
disclosure has been revised accordingly.

Comment
(11)    In the performance table for the Target Fund, the benchmark named is the MSCI ACWI Ex US Small-Cap Growth Index but it
appears to be the performance of the MSCI World Ex US Small Cap Growth Index.

 Response:           The benchmark has been revised to reference the MSCI World Ex US Small Cap Growth Index.

Comment
(12)    Please disclose which Fund will be the accounting survivor of the Reorganization. Supplementally explain the factors the
Registrant considered in making the accounting survivor determination.

 Response:         The Registrant has disclosed in the section entitled “The Proposed Reorganization” that the Acquiring Fund will be the accounting survivor of the Reorganization. Attached as Appendix A is the Registrant’s NAST analysis in support of the Acquiring Fund as the accounting survivor of the Reorganization. As discussed therein, the Registrant believes the Acquiring Fund’s longer performance track record favors the Acquiring Fund as the accounting survivor.

General

Comment
(13)    Please undertake to file the final tax opinion in a POS EX filing after the closing of the Reorganization.

 Response:           The Registrant undertakes to file the final tax opinion in a POS EX filing after the closing of the Reorganization.

*      *      *

U.S. Securities
and Exchange Commission

November 2, 2023

Page 4

Please call me at (312) 609-7616 if you have any questions.

    Very truly yours,

    /s/ Renee M. Hardt

    Renee M. Hardt

RMH/ser

Appendix A

NAST Analysis

Oberweis International Opportunities Institutional
Fund (the “Target Fund”) into Oberweis International Opportunities Fund (the “Acquiring Fund”) (the “Reorganization”)

The following is the accounting and performance
survivor analysis in connection with the Reorganization. The analysis is based on guidance provided by the American Institute of
Certified Public Accountants in the AICPA Accounting and Audit Guide for Investment Companies with Conforming Changes as of May 1,
2003, as amended (the “Audit Guide”), regarding the surviving entity for financial reporting purposes, and the
Accounting Policy Subcommittee of the Accounting/Treasurer’s Committee of the Investment Company Institute (“ICI”) in
a white paper on fund mergers dated March 1, 2004 (“ICI White Paper”), regarding accounting survivors, as well as on
the guidance of the staff of the Commission (the “Staff”) set forth in North American Security Trust, SEC No-Action
Letter (Aug. 5, 1994) (the “NAST Letter”), relating to performance survivors. The Audit Guide states that the legal survivor
would normally be considered the accounting survivor of a fund reorganization. In the NAST Letter, the Staff confirmed that, generally,
the survivor of a business combination for accounting purposes, i.e., the fund whose financial statements are carried forward, will be
the fund whose historical performance may be used by a new or surviving fund. The Staff in the NAST Letter and the ICI White Paper generally
identify the same factors that funds should compare in making this determination as those identified in the Audit Guide.

Portfolio Management: One of the primary
factors in determining the accounting and performance survivor is the surviving management structure. Both the Target Fund and the Acquiring
Fund (collectively the “Funds”) are currently advised by the same investment adviser and are currently managed by the same
portfolio manager. After the Reorganization, the same investment adviser and portfolio manager will continue to manage the combined fund’s
investment portfolio in the same manner in which the Funds are currently managed, and it is not expected that any holdings will be sold.

Portfolio
Composition: The surviving fund will operate under the investment objective, principal investment strategies and restrictions as the
Funds and the combined fund’s investment portfolio will be managed in the same manner in which the Funds are currently managed.

Investment
Objectives, Principal Investment Strategies and Restrictions: The investment objectives and principal investment strategies of
the Funds are the same. The Funds have identical fundamental investment restrictions.

Expense
Structure: Currently, the Funds have different fees and expense structures. At the time
of the Reorganization, the management fee of the Acquiring Fund will be reduced to be the same as the current management fee of the Target
Fund, and the expense limitation for the Acquiring Fund’s Institutional Class shares (the class into which the Target Fund will
be reorganized) will be the same as the expense limitation of the Target Fund.

Asset
Size: As of June 30, 2023, the Target Fund had net assets of approximately $314.9 million, and the Acquiring Fund had net assets of
approximately $133.6 million.

Additional Factors

The ICI White Paper states that the age of the
funds and the surviving fund’s board of directors are also items that figure in the determination of which fund historical performance
and financial information will be carried into the surviving fund.

    Appendix A – Page 1

Age of Funds: The Target Fund commenced
operations on March 10, 2014, while the Acquiring Fund commenced operations on February 1, 2007. Since the Acquiring Fund has a longer
track record, this factor favors the Acquiring Fund as the accounting and performance survivor.

Board Composition: Both Funds are
series of the Registrant and, as a result, have the same Board of Trustees.

Conclusion

As the acquiring fund, the Acquiring Fund will
be the legal survivor in the Reorganization, which, as noted above, generally suggests that the Acquiring Fund should also be the appropriate
accounting and performance survivor in the Reorganization. The Funds are identical in terms of the investment adviser, portfolio management,
portfolio composition, and principal investment strategies and restrictions. The expense
structure of the combined fund after the Reorganization will be the same as that of the Target Fund. Additionally, the Acquiring Fund
commenced operations prior to the Target Fund.

For these reasons, the Registrant believes that
current and future shareholders of the combined fund should consider the Acquiring Fund’s performance history more relevant to their
investment decisions than that of the Target Fund, and therefore believes that the Acquiring Fund should be the accounting and performance
survivor in the Reorganization.

Appendix A – Page 2