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Alger Portfolios Comment Response Letter

 THE ALGER PORTFOLIOS

100 Pearl Street, 27th Floor

New York, New York 10004

 August 1,
2023

 VIA EDGAR

 Securities and Exchange Commission

 100 F Street, N.E.

 Washington, D.C. 20549

Attn: Kimberly A. Browning, Ken Ellington and David Manion

Re:
 The Alger Portfolios (333-272370)

 Registration Statement on Form N-14

Dear Ms. Browning, Mr. Ellington and Mr. Manion:

On behalf of The Alger Portfolios (the “Registrant”), this letter responds to the comments provided by the staff of the Division of
Investment Management (the “Staff”) of the Securities and Exchange Commission (the “Commission”) to the undersigned by telephone on June 8, 2023 and to the undersigned and Mia G. Pillinger by telephone on June 30, 2023,
July 26, 2023 and July 27, 2023, regarding Registrant’s Registration Statement on Form N-14 (the “Registration Statement”) filed with the Commission on June 2, 2023 pursuant to
Rule 488 under the Securities Act of 1933, as amended (the “Securities Act”), related to the reorganization of Alger Weatherbie Specialized Growth Portfolio (the “Target Portfolio”), a series of the Registrant, into Alger Small
Cap Growth Portfolio (the “Acquiring Portfolio” and together with the Target Portfolio, the “Portfolios”), also a series of the Registrant (the “Reorganization”).

The Staff’s comments have been restated below in italicized text. The Registrant’s responses to the Staff’s comments are set
out immediately under the restated comment. The Registrant plans to file an amendment to the Registration Statement (the “Amendment”) on or about August 1, 2023, in order to reflect changes made in response to the Staff’s
comments. Unless otherwise indicated, defined terms used herein have the meanings set forth in the Registration Statement.

 ACCOUNTING COMMENTS

Comment No. 1:

The fee table is dated 12/31/2022. In accordance with Item 3 of Form N-14, please either confirm that the fees are still current as of the date of the
N-14 or update the fee table.

Response No. 1:

Registrant will update the fees in the fee table as of June 30, 2023 in the Amendment. Registrant notes for the Staff that the Board approved the Reorganization at its meeting on May 23, 2023, and therefore did not
consider the Portfolios’ fees as of June 30, 2023 in its determination.

 August 1, 2023

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Comment No. 2:

Please include numbers for the Acquiring Portfolio and the Combined Portfolio in the fee table for “Total Annual Fund Operating Expenses After Fee Waiver and/or Expense Reimbursement.”

Response No. 2:

Registrant will make the requested revisions in the Amendment.

Comment No. 3:

Please explain supplementally to the Staff the difference in the Target Portfolio’s “Other Expenses” and “Total Annual Fund Operating Expenses After Fee Waiver and/or Expense Reimbursement” as of
December 31, 2022 and June 30, 2023. The Staff notes that the difference in “Other Expenses” between the periods noted is 4.16% and the difference in Total Annual Fund Operating Expenses After Fee Waiver and/or Expense
Reimbursement” between the periods noted is 0.91%.

Response No. 3:

The Target Portfolio had approximately $2.8 million in average net assets as of December 31, 2022 and approximately $1.2 million in average net assets as of June 30, 2023. Additionally, under the Target
Portfolio’s expense reimbursement agreement with FAM, the Target Portfolio’s other expenses (excluding custody fees, acquired fund fees and expenses, dividend expense on short sales, net borrowing costs, interest, taxes, brokerage and
extraordinary expenses, to the extent applicable) are capped at 0.24% based on average daily net assets. As of December 31, 2022, the Target Portfolio had 0.04% of interest expenses which were not waived under the expense reimbursement
agreement and as of June 30, 2023, the Target Portfolio had 0.95% of custody expenses which were not waived under the expense reimbursement agreement. The Target Portfolio’s decrease in assets and the difference in other expenses which are
not waived under the expense reimbursement agreement contributed to the difference in “Other Expenses” and “Total Annual Fund Operating Expenses After Fee Waiver and/or Expense Reimbursement” as of December 31, 2022 and
June 30, 2023.

 DISCLOSURE COMMENTS

General Comments

Comment No. 4:

The Staff reminds Registrant that, in accordance with the Staff’s pronouncement on October 5, 2016, Registrant and its management are responsible for the accuracy and adequacy of Registrant’s disclosures,
notwithstanding any review, comments, action or absence of action by the Staff.

Response No. 4:

Registrant acknowledges this statement.

Comment No. 5:

The Staff notes that the comments apply to identical or similar disclosures throughout the Registration Statement, as applicable.

Response No. 5:

Registrant acknowledges this statement and has responded accordingly.

 August 1, 2023

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Comment No. 6:

If Registrant decides to decline a comment from the Staff, please include a well-reasoned and detailed analysis in support of Registrant’s decision.

Response No. 6:

Registrant acknowledges this request and has responded accordingly, where applicable.

Comment No. 7:

Registrant makes statements throughout the Registration Statement regarding the anticipated goals or benefits of the Reorganization. For purposes of a fair and balanced representation, wherever such statements appear, the
Staff requests Registrant temper such statements with clarification that the goals or benefits may not be achieved, and that the benefits are not guaranteed.

Response No. 7:

Registrant will make the requested revisions in the Amendment.

Shareholder Letter

Comment No. 8:

The fourth paragraph of the Shareholder Letter states that “the Board determined that the Reorganization is in the best interests of the Target Portfolio and the Acquiring Portfolio and that the interests of the existing
shareholders of the Target Portfolio and the Acquiring Portfolio will not be diluted as a result of the Reorganization.” If the Board made any best interest determinations with respect to shareholders of the Target Portfolio or the Acquiring
Portfolio, please inform the Staff and harmonize the disclosure in the Shareholder Letter, Q&As and the Prospectus/Information Statement regarding these determinations.

Response No. 8:

As discussed in the section of the Prospectus/Information Statement entitled “Prospectus/Information Statement—Information About the Reorganization—Reasons for the Reorganization” the Board considered the
potential benefits and costs to shareholders of the Portfolios. However, because there is no requirement under Rule 17a-8 under the 1940 Act for a board to determine that a merger be in the best interests of a
merging company’s shareholders, the Board did not make a best interest determination with respect to shareholders of the Portfolios. Registrant will add a cross reference in the Shareholder Letter to the section of the Registration Statement
entitled “Information About the Reorganization—Reasons for the Reorganization” in the Amendment to direct shareholders to the Board’s considerations, including potential benefits and costs to Portfolio shareholders.

Comment No. 9:

The fifth paragraph of the Shareholder Letter discusses the tax-free nature of the Reorganization, but does not include disclosure stating that the
tax-free status of the Reorganization will be based on the opinion of tax counsel, as is stated elsewhere in the Registration Statement. Please add disclosure regarding the opinion of tax counsel in the
Shareholder Letter.

 August 1, 2023

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Additionally, the language regarding the tax-free nature of the Reorganization is anticipatory. Please confirm to the Staff whether receipt of a satisfactory opinion of tax counsel is a
non-waivable condition of the Reorganization. If it is, revise the language in the Registration Statement to state definitively that the Reorganization will be tax-free, rather than stating that it is
anticipated to be tax-free.

Response No. 9:

Registrant will revise the Shareholder Letter in the Amendment to state that “As a condition to the closing of the Reorganization, the Target Portfolio and the Acquiring Portfolio will receive an opinion of counsel to the
effect that, for U.S. federal income tax purposes and under currently applicable U.S. federal income tax law, the Reorganization will be treated as a “reorganization” within the meaning of Section 368(a) of the Code.”

Registrant confirms that receipt of a satisfactory opinion of tax counsel is a non-waivable condition of the Reorganization. Registrant notes, however, that the Registration Statement is filed pursuant to Rule 488 under the
Securities Act and will become effective prior to the closing of the Reorganization, which is anticipated to be on or about September 29, 2023. Because counsel will not issue its opinion until the closing of the Reorganization, Registrant
cannot make definitive statements regarding the tax-free nature of the Reorganization or counsel’s opinion.

Q&As (Important Information to Help You Understand the Reorganization)

Comment No. 10:

Please revise the answer to question 3 to mirror the disclosure elsewhere in the Registration Statement regarding the pro rata distribution of shares and fractional shares. Please also clarify the valuation date in the answer
to question 3.

Response No. 10:

The answer to question 3 will be revised in the Amendment as follows:

You will become a shareholder of the Acquiring Portfolio, on or about September 29, 2023 (the “Closing Date”), and will no longer be a shareholder of the Target Portfolio. On the Closing Date, the Acquiring
Portfolio shares received by the Target Portfolio will be distributed to Target Portfolio shareholders, and you will receive a pro rata distribution of the Acquiring Portfolio’s shares (or fractions thereof) for Target Portfolio shares
held prior to the Reorganization. You will receive for your Target Portfolio shares a number of Class I-2 shares (or fractions thereof) of the Acquiring Portfolio with an aggregate net asset value equal
to the aggregate net asset value of your Class I-2 shares as of the Closing Date. The Target Portfolio will then cease operations and will be terminated as a series of the Trust. The Acquiring Portfolio
will be the accounting and performance survivor of the Reorganization, and the combined portfolio resulting from the Reorganization is sometimes referred to herein as the “Combined Portfolio.”

 August 1, 2023

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Comment No. 11:

The second paragraph of the answer to question 4 includes a discussion of the Portfolios’ net expense ratios, after taking into consideration expense reimbursement arrangements. For the purpose of avoiding misleading
disclosure and for accuracy, please also include a discussion of the Portfolios’ gross expense ratios prior to the reimbursement of any expenses.

Response No. 11:

Registrant will revise the answer in the Amendment, and the relevant disclosure throughout the Amendment, to include disclosure regarding both the gross and net expense ratios for the Portfolios.

Comment No. 12:

The answer to question number 5 states that the advisory fee rates for the Target Portfolio and the Acquiring Portfolio are identical, but does not address any other potential material differences between the Portfolios’
investment advisory agreements. Please add this disclosure.

Response No. 12:

Registrant will revise the disclosure to state that the investment advisory agreement for the Portfolios is between the Manager and Registrant, and, since both Portfolios are series of Registrant, they have the same investment
advisory agreement.

Comment No. 13:

With respect to the Target Portfolio’s expense reimbursement agreement discussed in the answer to question 5, please (i) supplementally confirm to the Staff whether the agreement is separate from Registrant’s
investment advisory agreement, (ii) clarify that the expense limitation will not carry over to the Acquiring Portfolio and that the Acquiring Portfolio does not currently have an expense reimbursement agreement, and (iii) supplementally
explain to the Staff, if there are recoupment privileges under the expense reimbursement agreement, the consequences of such recoupment after the Closing Date of the Reorganization and whether they will continue. Please consider adding a separate
Q&A regarding the expense reimbursement agreement of the Target Portfolio.

Response No. 13:

Registrant will revise the disclosure to state that the Acquiring Portfolio does not have an expense limitation agreement and that the Target Portfolio’s expense limitation agreement will not carry over to the Acquiring
Portfolio.

Registrant confirms to the Staff that the expense limitation agreement between Registrant and the Manager is separate from Registrant’s investment advisory agreement. Registrant further confirms to the Staff that the Manager
has agreed not to recoup any fees waived or expenses reimbursed pursuant to the expense limitation agreement with the Target Portfolio upon completion of the Reorganization. While this is disclosed in the Prospectus/Information Statement, Registrant
will add disclosure regarding the recoupment in the answer to question 5 as well.

 August 1, 2023

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Registrant believes the discussion regarding the Target Portfolio’s expense limitation agreement is appropriately discussed in its answer to question number 5 and respectfully declines to add a separate Q&A regarding
this agreement. Registrant has, however, divided the response to question 5 into sections regarding the different types of fees and expenses of the Portfolios, which includes a separate section regarding the Target Portfolio’s expense
limitation agreement.

Comment No. 14:

The third paragraph of the answer to question 5 states that “FAM pays a sub-advisory fee to WC out of its own resources at no additional charge to the Target
Portfolio[●]” Please revise to say that FAM pays a sub-advisory fee to WC out of its own “legitimate profits.” Additionally, please note that the Staff considers sub-advisory
fees to be fees payable by a fund, regardless of whether such fees are paid directly by a fund to a sub-advisory or indirectly through an adviser (see Proposed Rule: Exemption from Shareholder Approval for
Certain Subadvisory Contracts, IC-26230 (Oct. 23, 2003), at note 22). The Staff therefore considers disclosure under Item 19(a)(3) of Form N-1A to be required with
respect to sub-advisory fees, as well as advisory fees.

Response No. 14:

Registrant will make the requested revision in the Amendment. Registrant acknowledges the Staff’s position regarding sub-advisory fees and notes that the SAI, including disclosure in
response to Item 19(a)(3) under Form N-1A, is incorporated into the Registration Statement by reference in accordance with General Instruction F, Part B to Form
N-14.

Comment No. 15:

The final sentence of the first paragraph of the answer to question 7 states that distribution of any undistributed net investment income and net realized capital gains (after reduction for any capital loss carryforwards)
prior to the Reorganization will be taxable to shareholders. Please clarify how this is true if the Reorganization is intended to qualify as a tax-free reorganization for U.S. federal income tax
purposes.

Response No. 15:

Although the Reorganization itself is intended to qualify as a tax-free reorganization for U.S. federal income tax purposes, any portfolio repositioning of the Target Portfolio prior
to the Reorganization could generate capital gains for Target Portfolio shareholders, to the extent such shareholders hold Target Portfolio shares in taxable accounts. This is consistent with the requirements of Section 368(a) of the Code.
Registrant will revise the final sentence of the first paragraph of