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CORRESP
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CORRESP

 March 13, 2023

 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

 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”)

 Files 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. 344 (“PEA 344”) to the Registrant’s registration statement under the Securities Act of 1933, as amended, and Amendment No. 487 to the Registrant’s registration statement under the Investment
Company Act of 1940, as amended (the “1940 Act”), as filed on December 27, 2022. PEA 344 was filed to register Institutional Class, Class I-2,
Class I-3, Administrative Class, Class A and Class C shares of PIMCO Total Return Fund V (the “Fund”), a new series of the Registrant. 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 344.

Prospectus—Fee Table

 Comment
1: Please add a footnote to the fee table related to the fee waiver arrangement to disclose who can terminate the waiver agreement, the term of the waiver agreement and whether PIMCO may recoup any waived fees. Instruction 3(e) to Item 3 of Form
N-1A.

 Response: The Registrant confirms that applicable footnote disclosure will be
included in the registration statement.

 Comment 2: Confirm that the contractual waiver agreement referenced in the fee table will
be filed as an exhibit to the registration statement.

 Response: The Registrant confirms that the applicable agreement will be
filed as an exhibit to the Fund’s registration statement.

 Prospectus—Principal Investment Strategies

Comment 3: The Fund’s principal investment strategies state:

The Fund will not invest in the securities of any non-governmental
issuer determined by PIMCO to be engaged principally in the (1) manufacture of alcoholic beverages, tobacco products or military equipment, (2) operation of gambling casinos, (3) oil industry, including extraction, production, and
refining, or (4) production or distribution of coal and coal fired generation. In addition, the Fund will not invest in the securities of any non-governmental issuer known to (1)

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derive gross revenue from the production, direction or publication of adult entertainment materials, as well as those known to be directly engaged in the business of distributing and selling such
materials, (2) provide abortions or manufacture abortifacients (and entities that own or are owned thereby), (3) manufacture products intended for contraception, (4) engage in certain types of stem cell research (including the use of
embryonic or fetal stem cells to develop products), or (5) produce and/or retail cannabis for recreational use, each of the foregoing generally as determined by a third-party data provider and reported to PIMCO.

Please disclose, either in this section or in response to Item 9 of Form N-1A, the types of businesses
that would be excluded from investment pursuant to each prong of this policy.

 Response: The following disclosure will be added to
the prospectus section “Characteristics and Risks of Securities and Investment Techniques—Additional Information Regarding Certain Screens Used by the Fund”:

Adult Entertainment Producers, Distributors and Retailers. Adult entertainment materials generally are
those in which the dominant theme is “sexually explicit” conduct. Companies involved in the independent wholesale of such materials generally are viewed as distributors thereof. In addition, companies that operate specialty stores or
online sites for adult entertainment materials generally are viewed as retailers thereof.

 The Registrant has reviewed the Fund’s
principal investment strategies, “Characteristics and Risks of Securities and Investment Techniques—ESG Investing” and “Characteristics and Risks of Securities and Investment Techniques—Additional Information Regarding
Certain Screens Used by the Fund” and believes that, with the additional disclosure indicated above, the disclosure included in the prospectus effectively describes the types of businesses that would be excluded from investment based on the
screens described in the Fund’s principal investment strategies.

 Comment 4: The Fund’s principal investment strategies
state, “the Fund will not invest in the securities of any non-governmental issuer known to … provide abortions or manufacture abortifacients (and entities that own or are owned thereby)”. Please
define “abortifacients” within the principal investment strategies section of the prospectus.

 Response: The Registrant
has reviewed the prospectus disclosure and believes the following definition within “Characteristics and Risks of Securities and Investment Techniques—Additional Information Regarding Certain Screens Used by the Fund – Abortion
Providers and Abortifacient Manufacturers” is responsive to the comment, particularly the first sentence within the parenthetical:

Abortion Providers and Abortifacient Manufacturers. This screen generally is intended to exclude
companies with an industry tie to abortion or abortifacients, including abortion providers, acute care facility operators, abortifacient manufacturers, and issuers that own or are owned by one of the foregoing. (Abortifacients generally are drugs,
compounds or chemicals that result in the termination of a pregnancy or that are otherwise recognized as having significant secondary use in the termination of pregnancy. The following are not intended to be excluded: companies that solely market,
license, or distribute abortifacients; companies that manufacture non-abortifacient specific products such as saline solution; companies that retail or prescribe abortifacients, such as pharmacies; companies
that manufacture abortifacient drugs exclusively for research or animal use; and/or companies that produce drugs that include abortion as a side effect.)

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 Comment 5: With respect to (1)-(5) in the sentence beginning “In addition, the
Fund will not invest in the securities of any non-governmental issuer known to…” please disclose the criteria utilized to determine whether an issuer is “known to” be involved in such
activities. If a revenue criteria is utilized for issuers engaged in stem cell research, please explain how that is appropriate given research is likely an expense rather than a contributor to revenue.

Response: The Registrant has reviewed the section of the prospectus entitled “Characteristics and Risks of Securities and
Investment Techniques—Additional Information Regarding Certain Screens Used by the Fund” and believes that, with the additional disclosure indicated in the response to Comment 3 above, the disclosure included in the prospectus effectively
describes the criteria utilized to determine whether an issuer is “known to” be involved in the specified activities. With regard to stem cell research providers, as disclosed in the prospectus, stem cell research providers will be
identified through screens that seek to identify issuers that are “engaged in stem cell research using cells derived from human embryos or human fetal tissue, companies that use fetal cell lines in the development of vaccines and other
biologics, companies that develop or produce products for scientific research specifically on embryonic or fetal stem cells and companies that use embryonic or fetal stem cells to develop products” without regard to revenue.

Comment 6: The Fund’s principal investment strategies state:

In analyzing whether an issuer meets any of the criteria described above, PIMCO may rely upon, among other
things, information provided by an independent third party, including research and screens employed for certain values-based or Catholic institutions such as the MSCI Catholic Values Screening Methodology and related research.

If PIMCO will rely upon third party research and screens, such as MSCI Catholic Values Screening Methodology, please replace “may”
with “will.”

 Response: The Registrant has revised the referenced disclosure to note that PIMCO “intends to
predominantly rely upon” third party research and screens, as also noted by the Staff in connection with comment 18 below.

Comment 7: The Fund intends to utilize data from third party providers to screen investments. Please identify any primary providers the
Fund will use in addition to MSCI. Please also briefly summarize each provider’s screening methodology in the prospectus, and consider any related principal risks to the Fund resulting from the use of third party providers given the criteria
used by multiple providers can differ significantly in relation to each other.

 Response: PIMCO is not currently contemplating
utilizing other third party providers to screen investments in addition to MSCI. The Registrant believes the current risk disclosure regarding Environmental, Social and Governance and Faith-Based Values Investing Risk is sufficient in that it
discloses “there is no guarantee that the factors utilized by PIMCO or any judgment exercised by PIMCO will reflect the opinions of any particular investor, and the factors utilized by PIMCO may differ from the factors that any particular
investor considers relevant”.

 Comment 8: The Fund’s principal investment strategies state:

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

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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 expectation that these practices may improve over time either
as a result of PIMCO’s engagement efforts or through the company’s own initiatives. It may also exclude those issuers that are not receptive to PIMCO’s engagement efforts, as determined in PIMCO’s sole discretion.

 Please disclose specific environmental, social and/or governance practices that PIMCO will consider on behalf of the Fund.

Response: The Registrant believes the current disclosure covers the material aspects of the environmental, social and/or governance
practices that PIMCO will consider on behalf of the Fund.

 Comment 9: Please disclose whether the Fund’s investments in
(1) derivative instruments and (2) mortgage- or asset-backed securities are subject to the Fund’s ESG and Faith-Based Values Investing screens. If not, please disclose that such investments are made without reference to the
Fund’s ESG and Faith-Based Values Investing screens, or disclose the actual screens that apply to such investments.

 Response:
As disclosed in the statement of additional information, the Fund will not invest in derivative instruments whose returns are based, in whole, on securities issued by Total Return V Socially-Restricted Issuers. The Fund’s principal investment
strategies state that the Fund may invest in derivatives, such as credit default swaps, on indexes of securities which may include exposure to issuers that the Fund is not permitted to invest in directly.

With respect to mortgage- and asset-backed securities, the Registrant notes that the disclosure currently states that the referenced screens
are applied to “non-governmental issuers,” but the Registrant will add further disclosure to state that issuers of mortgage- and asset-backed securities generally will not be treated as Total Return
V Socially-Restricted Issuers.

 Prospectus—Principal Risks

Comment 10: In the “Principal Risks–Leveraging Risk” section, the Fund references reverse repurchase agreements but does
not include corresponding disclosure in the Principal Investment Strategies. If reverse repurchase agreements are not part of the Fund’s principal strategies, please tailor the risk factor to only reference the types of leverage the Fund will
principally engage in.

 Response: The Registrant believes that the current disclosure is adequate. The Registrant does not consider
reverse repurchase agreements to be part of the Fund’s principal investment strategies, but notes that such reverse repurchase agreements may contribute to leveraging risk. In addition, the Registrant notes that reverse repurchase agreements on
Fixed Income Instruments are included within the defined term “Fixed Income Instruments,” which is what the Fund primarily invests in as set forth in the Fund’s principal investment strategies.

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 Comment 11: In the “Principal Risks – Environmental, Social and Governance
and Faith-Based Values Investing Risk” section, consider replacing “performance will differ from funds that do not utilize an ESG investing strategy” with “performance may be less than funds that do not utilize an
ESG investing strategy.”

 Response: The Registrant has reviewed the disclosure and believes that the use of “performance
will differ from,” rather than “performance may be less than” accurately describes Environmental, Social and Governance and Faith-Based Values Investing Risk. The Registrant respectfully declines to make the requested change.

Comment 12: Consider adding disclosure, where applicable, regarding how the Fund will handle relevant ESG and Faith-Based Values
Investing considerations in voting proxies with respect to portfolio holdings of the Fund.

 Response: The Registrant believes that
additional disclosure is unnecessary and unlikely to be useful to investors or prospective investors, as the Fund will invest primarily in fixed income securities that generally are not voting securities. Additionally, the Trust respectfully notes
that Instruction 2 to Item 17(f) of Form N-1A provides that “[a] Fund may satisfy the requirement to provide a description of the policies and procedures that it uses to determine how to vote proxies
relating to portfolio securities by including a copy of the policies and procedures themselves.” As the proxy voting policy is included in the SAI, the Registrant respectfully declines to add additional disclosure.

Prospectus—Performance

 Comment
13: Please provide supplementally the name of the Fund’s broad-based securities market index.

 Response: The Fund’s
broad-based securities market index is the Bloomberg Barclays U.S. Aggregate Index.

 Prospectus—Management

Comment 14: In the “Management of the Fund – Management Fees – Advisory Fees” section, please insert the text of
footnote 1.

 Response: Comment accepted. The footnote will state: “This Fund was not operational as of the date of this
prospectus.”

 Comment 15: The “Management of the Funds – Individual Portfolio Managers” section of the
prospectus, please identify the lead portfolio manager(s) who is (are) primarily (jointly and primarily) responsible for the day-to-day management of the Fund.

Response: Comment accepted.

Prospectus—Distribution and Servicing (