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CORRESP
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CORRESP

 1900 K Street, NW

 Washington, DC 20006-1110

+1   202   261   3300   Main

 +1
  202   261   3333   Fax

 www.dechert.com

 Adam T.
Teufel

 adam.teufel@dechert.com

+1 202 261 3464 Direct

 +1 202 261 3164 Fax

 January 7, 2020

VIA EDGAR

 Anu Dubey

Division of Investment Management

U.S. Securities and Exchange Commission

100 F Street, N.E.

 Washington,
D.C. 20549

Re:
 PIMCO Funds (the “Registrant”)

 File Nos. 033-12113; 811-05028

 Dear Ms. Dubey:

You previously communicated the Securities and Exchange Commission (“SEC”) staff’s (the “Staff”)
comments on Post-Effective Amendment No. 328 (“PEA 328”) to the Registrant’s registration statement under the Securities Act of 1933, as amended, and Amendment No. 454 to the Registrant’s registration statement under
the Investment Company Act of 1940, as amended (the “1940 Act”), as filed on November 15, 2019. PEA 328 was filed to register Class A and Class C shares of PIMCO Total Return ESG Fund, an existing series of the Registrant
(the “Fund”). A summary of the Staff’s comments, along with the Registrant’s responses, is set forth below. Undefined capitalized terms used herein have the same meaning as in PEA 328. All references to “Fund” refer
only to the Fund, unless noted otherwise.

 Prospectus

Comment 1: As required by Rule 423 under the 1933 Act, please confirm that the date on the prospectus cover will be
approximately the date that the amended prospectus will become effective without reference to an earlier date “as supplemented.”

Response: The Registrant acknowledges the Staff’s request to date any prospectuses included in post-effective
amendments to its registration statement as of the date the amendment will become effective. The sole purpose of PEA 328 was to register Class A and Class C shares of the Fund. In lieu of creating a standalone new prospectus solely for two
new classes of an existing Fund, the Registrant updated the existing multi-series, multi-class prospectus for that Fund, dated July 31, 2019, to add the new classes. The definitive post-effective amendment for this purpose will be filed on or
around January 14, 2020 (“485(b) PEA”). The prospectus in the 485(b) PEA will be dated “July 31, 2019 (as supplemented January 14, 2020).” Just as in PEA 328, the prospectus in the 485(b) PEA will include a number of
other series and classes of the Registrant in addition to

Anu Dubey
 January 7, 2020

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the two new classes of the Fund, and PEA 328 was, and 485(b) PEA will be, filed under the new class identifiers for the Fund only, not the identifiers of all of the other series and classes that
were included in the prospectus within each of PEA 328 and the 485(b) PEA. Such other series and classes were included for administrative convenience in recognition of the fact that the Registrant always intended to offer the new classes of the
Fund, together with other funds and their classes, in the existing July 31, 2019 prospectus, not in a new standalone prospectus dated January 14, 2020.

An alternative approach would have been to draft and file a new standalone prospectus solely for the new classes of the Fund,
via post-effective amendment dated January 14, 2020, and immediately supersede that filing with a 497 filing incorporating the newly effective classes of the Fund within the existing July 31, 2019 prospectus with a dating convention of
“July 31, 2019 (as supplemented January 14, 2020).” In other words, the Registrant could create two different sets of prospectuses, one of which would be used solely for PEA 328 and then discarded, the other used for a subsequent 497
filing and actual delivery to shareholders. We respectfully assert that such alternative approach would have created substantial administrative burdens and costs for no discernible benefit, solely to ensure that the prospectus within PEA 328 was
dated in technical conformance with Rule 423. For these reasons, we respectfully assert that the dating convention used in PEA 328 was appropriate as is.

Comment 2: In the “Fees and Expenses of the Fund” section of the Fund’s Fund Summary, please add
disclosure regarding sales charge discounts and referencing Appendix B, consistent with other Funds that offer Class A shares.

Response: Comment accepted.

Comment 3: The Fund includes a fee table footnote relating to the Fund’s interest expense. Such footnote is
neither permitted nor required by Form N-1A. Please delete. As an alternative approach to the interest expense related footnotes, consider adding a parenthetical or
sub-caption line item to the “Other Expenses” line item that identifies interest expense, which is permitted by Form N-1A.

Response: The Registrant has previously reviewed its funds’ interest expense footnotes in light of the
Staff’s comment and has already consolidated such footnotes into a single footnote per fund fee table, consistent with the Staff comment provided to the 2016 annual update of the PIMCO Funds’ registration statement. However, the Registrant
respectfully declines to delete these footnotes in their entirety. The Registrant’s response, set forth below, is the same as the response provided to similar comments to several prior post-effective amendments of PIMCO-advised registrants.

 To the extent the Fund enters into certain investments, such as reverse repurchase agreements or short sales, the Fund
incurs interest expense. Interest expense is required to be treated as an expense of the Fund for accounting purposes, but the amount of interest expense, if any, will vary from year to year with the Fund’s use of such investments as an
investment strategy.

Anu Dubey
 January 7, 2020

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 Unlike many other fund complexes, the Fund has a “unified fee”
structure wherein the Fund pays two fixed fees to PIMCO in return for required services that PIMCO provides or arranges to provide for the Fund. This unified fee is comprised of the investment advisory fee and supervisory and administrative fee as
described in the Fund’s statutory prospectus and disclosed in the combined Management Fees line item of the fee table. Under the unified fee, PIMCO provides or procures advisory and supervisory and administrative services for shareholders and
also bears the costs of various third-party services required by the Fund, including audit, custodial, portfolio accounting, legal, transfer agency and printing costs. As such, the unified fee structure is designed to be an “all-in” fee structure that pays for the fees and costs of all PIMCO and third-party provided services under more or less a fixed fee. Accordingly, the Registrant believes that investors have come to
expect a total expense ratio from year to year that is generally fixed.

 There are, however, certain expenses the Fund
does bear that are not covered under the unified fee structure that may materially impact the total level of expenses that shareholders generally expect to pay under a unified fee structure. One of the few expenses not covered by the unified fee,
and thus reflected in the “Other Expenses” line item of the fee table, is the Fund’s interest expense. As interest expense may vary, causing the Fund to disclose a different total expense ratio from year to year, the Registrant
believes that failure to include an explanation for this variance may create investor confusion. The Registrant believes an explanatory footnote appropriately placed where it is most likely to be read by investors (i.e., immediately adjacent to the
fee table and expense ratio) is helpful and informative for the average investor, not confusing or burdensome.

 The
Registrant notes that the SEC, in adopting the summary prospectus amendments to Form N-1A, indicated that “[t]he fee table and example are designed to help investors understand the costs of investing in a
fund and compare those costs with the costs of other funds” (emphasis added). The SEC further stated that the “prospectus summary section is intended to provide investors with streamlined disclosure of key mutual fund information at the
front of the statutory prospectus, in a standardized order that facilitates comparisons across funds” (emphasis added). The Registrant agrees. The primary goal of a statutory prospectus summary section should be to provide clear, concise
information to facilitate investor comparison of the Fund with other mutual funds. Without the current fee table footnote describing the Fund’s interest expense and its effect on the Fund’s expense ratio, the Registrant believes the
Fund’s fee table would not adequately facilitate an investor comparison of the Fund’s costs against other mutual funds’ costs as investors will not have the context in which to accurately make such a comparison. Because the Fund has a
unique unified fee structure as described above, what comprises “Other Expenses” for the Fund is likely very different from what comprises “Other Expenses” for other mutual funds. Therefore, the impact of “Other
Expenses” on the Fund’s total expense ratio from year to year as compared to other mutual funds’ expense ratios is likely to be quite different. For example, because the Fund does not include any routine servicing or administrative
expenses under “Other Expenses,” as such expenses are covered by the unified fee, any “Other Expenses” reflect non-routine activities such as interest expense accrued as a result of
discretionary investment activities. Because the unified fee structure

Anu Dubey
 January 7, 2020

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renders “Other Expenses” a non-routine line item for the Fund, investors in the Fund have reasonably come to expect that the total expense ratio
of the Fund is often the unified fee plus any share class-specific fixed expenses (such as 12b-1 fees). Thus, without the footnote to explain the non-routine instances
where the Fund needs to disclose “Other Expenses,” investors may not understand that the Fund operates under a unified fee structure, as they may mistakenly assume that such “Other Expenses” are expenses that are in fact covered
by the unified fee. This is particularly true under the “summary prospectus” paradigm where the statutory prospectus is not required to be sent unless the investor requests it and detailed information about the unified fee structure is
only included in the statutory prospectus. Accordingly, the Registrant believes an investor could be unaware of the Fund’s unified fee structure unless the Fund includes an explanatory footnote in the summary prospectus. The Registrant believes
deleting the footnote would cause the Fund’s fee table to fall short in meeting the SEC’s objective of providing clear, concise, standardized information to facilitate cost comparisons across different mutual funds because the
Registrant’s unified fee structure is unique as compared to most other mutual funds.

 Thus, as General Instruction
C(1)(a) to Form N-1A states that the requirements of the Form are “intended to promote effective communication between the [Fund] and prospective investors,” the Registrant believes it is
“effective communication” within the meaning of the General Instruction to include a footnote as part of the fee table to clearly communicate the nature and amount of the Fund’s interest expense, where applicable, including why
interest expense is incurred and that interest expense may vary from year to year (i.e., that it is not a fixed fee or expense, like the other line items in the Fund’s fee table). The Registrant believes the failure to do so may result in
investors not otherwise understanding why the Fund’s total expense ratio may differ, sometimes substantially, each year largely as a function of interest expense. Moreover, the inclusion of the interest expense footnotes, in addition to
providing clarifying information to investors, does not lengthen the summary section of the statutory prospectus in any meaningful way or otherwise interfere with a concise, plain English presentation of material information to investors. To the
contrary, the interest expense footnotes provide helpful, clarifying information for investors.

 The Registrant has
considered the alternative approaches suggested by the Staff and has respectfully determined not to make changes at this time.

Comment 4: Pursuant to Instruction 3(e) to Item 3 of Form N-1A, a fee waiver
may be disclosed in the fee table only if it will be in effect for at least one year from the effective date of the prospectus. Please revise the disclosure for all funds in the prospectus accordingly.

Response: As explained in response to Comment 1 above, PEA 328 was filed only to register Class A and
Class C shares of the Fund. Accordingly, PEA 328 did not amend the registration statement for other series and classes of the Registrant. Therefore, the Registrant was under no obligation to update the terms of its contractual fee waivers with
respect to such other series and classes.

Anu Dubey
 January 7, 2020

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 Comment 5: Since the use of “ESG” in the Fund’s name
suggests investment in the securities of issuers with certain business practices with respect to the environment, social responsibility, and governance (“ESG Investments”), the Fund should adopt a names rule policy to invest at least 80%
of its assets in ESG Investments. Please disclose such a policy for the Fund and also add specific criteria to the Fund’s Principal Investment Strategies section. See Rule 35d-1(a)(3)(ii), which requires
prospectus disclosure of “specific criteria” used by the Fund to select investments pursuant to its names rule policy.

Response: The Registrant respectfully declines to revise the Fund’s prospectus to include an 80% policy related
to “ESG” in the Fund’s name. Rule 35d-1 under the 1940 Act requires that a fund adopt an 80% policy in three situations: (i) when it has a name suggesting investment in certain investments
or industries; (ii) when it has a name suggesting investment in certain countries or geographic regions; and (iii) when it has a name suggesting it is exempt from federal income tax or from both federal and state income tax.

The Registrant does not believe that the term “ESG” is a term that falls under any of the three categories outlined
in Rule 35d-1. “ESG” does not suggest investment in certain industries, countries or geographic regions or suggest that the Fund is exempt from any tax. The term “ESG” is not specifically
addressed in the Rule 35d-1 adopting release or the Staff’s guidance regarding frequently asked questions about Rule 35d-1, in which the Staff distinguished between
a term that suggests an investment objective or strategy and a term that suggests a type of investment. As used by the Fund, the term “ESG” describes a strategy and not a particular type of investment. As described in the Fund’s
principal investment strategies:

 The Fund may avoid investment in the securities of issuers whose
business practices with respect to the environment, social responsibility, and governance (“ESG practices”) are not to PIMCO’s satisfaction. In determining the efficacy of an issuer’s ESG practices, PIMCO will use its own
proprietary assessments of material ESG issues and may also reference standards as set forth by recognized global organizations such as entities sponsored by the United Nations. Additionally, PIMCO may engage proactively with issuers to encourage
them to improve their ESG practices. PIMCO’s activities in this respect may include, but are not limited to, direct dialogue with company management, such as through in-person meetings, phone calls,
electronic communications, and letters. Through these engagement activities, PIMCO seeks to identify opportunities for a company to improve its ESG practices, and will endeavor to work collaboratively with company management to establish concrete
objectives and to develop a plan for meeting these objectives. The Fund may invest in securities of issuers whose ESG practices are currently suboptimal, with the ex