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        Sidley Austin LLP

        787 Seventh Avenue

        New York, NY 10019

        +1 212 839 5300

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AMERICA · ASIA PACIFIC · EUROPE

         +1 212 839 8679

MKUTNER@sidley.com

November 26, 2021

Jaea Hahn

Senior Counsel

U.S. Securities and Exchange Commission

Division of Investment Management, Disclosure Review and Accounting Office

100 F. Street, N.E.

Washington, DC 20549

    Re:
    First Eagle Funds (the “Trust”)

    File Nos.:  033-63560 and 811-7762

    Post-Effective Amendment No. 102 to the Trust’s Registration Statement on Form N-1A

Dear Ms. Hahn:

Thank you for your comments regarding Post-Effective
Amendment No. 102 to the Trust’s registration statement on Form N-1A, filed with the Securities and Exchange Commission (the
“Commission”) on September 10, 2021 (the “PEA”). The PEA was filed for the purpose of registering shares
of the First Eagle Global Real Assets Fund (the “Fund”), a new series of the Trust. This letter responds to your comments,
which you provided to us by telephone on October 26, 2021 and on November 22, 2021.

Below, we describe changes the Trust will
make to the PEA in response to the Staff’s comments, generally described by reference to where the responsive disclosures
will appear in the PEA. We expect that on November 23, 2021, the Trust will file a post-effective amendment to its registration
statement to delay the effectiveness of the PEA until November 30, 2021. We anticipate making the applicable changes in a filing
pursuant to Rule 485(b) under the Securities Act of 1933, as amended (the “Securities Act”), on or about November 30,
2021.

All text changes described below will be
implemented substantially as noted here, though some variation in the final filing may be appropriate.

Capitalized terms used, but not otherwise
defined, have the meaning ascribed to them in the PEA.

Sidley Austin (NY) LLP is a Delaware limited
liability partnership doing business as Sidley Austin LLP and practicing in affiliation with other Sidley Austin partnerships.

Page 2

GENERAL COMMENTS

 1. COMMENT: You asked that the Fund please provide its responses to the Staff’s comments
no later than five business days prior to the effective date of the filing to give the Staff adequate time to review the Fund’s
responses. You noted that the Fund and management are responsible for the accuracy of the disclosure notwithstanding any review
by the Staff.

RESPONSE: The Fund’s
responses to the Staff’s comments are included herein.

 2. COMMENT: You noted that where a comment is made to one section of the PEA, the comment
is applicable to all similar disclosure appearing elsewhere in the PEA.

RESPONSE: The Fund will
incorporate the Staff’s comments throughout the PEA.

FEES AND EXPENSES

 3. COMMENT: You asked the Fund to consider including percentage symbols after the stated
Maximum Sales Charge (Load) and Maximum Deferred Sales Charge amounts.

RESPONSE: The Fund respectfully
declines to make the change to the PEA. The Fund notes that the parentheticals in the Shareholder Fees section of the Fees and
Expenses table indicate that the sales charges are reflected “as a percentage. . . .”

 4. COMMENT: You asked the Fund to supplementally confirm that the: (1) Subsidiary’s
management fee, including any performance fee, will be included in Management Fees, and the Subsidiary’s expenses will be
included in Other Expenses in the Fee Table;(2) Subsidiary’s board will agree to inspection by the Staff of the Subsidiary’s
books and records, which will be maintained in accordance with Section 31 of the Investment Company Act and rules thereunder; and
(3) Subsidiary and its Board will agree to designate an agent for service of process in the United States.

RESPONSE: The Fund confirms
that the: (1) Subsidiary’s management fee, including any performance fee, will be included in Management Fees, and the Subsidiary’s
expenses will be included in Other Expenses in the Fee Table; (2) Subsidiary’s board has agreed to inspection by the Staff
of the Subsidiary’s books and records, which will be maintained in accordance with Section 31 of the Investment Company Act
and rules thereunder; and (3) Subsidiary and its Board have agreed to designate an agent for service of process in the United States.

 5. COMMENT: You asked the Fund to provide a completed Fee Table and Expense Examples for
the Staff’s review.

Page 3

RESPONSE: The completed
Fee Table and Expense Examples are as follows:

    Class A
    Class I
    Class R6

    Shareholder Fees (fees paid directly from your investment)

    Maximum Sales Charge (Load) on Purchases (as a percentage of public offering price)
    5.00
    None
    None

    Maximum Deferred Sales Charge (Load) (as a percentage of the lesser of your purchase or redemption price)
    1.00*
    None
    None

    Annual Fund Operating Expenses (expenses you pay each year as a percentage of the value of your investment)

    Management Fees**
     0.65
    0.65
    0.65

    Distribution and/or Service (12b-1) Fees
    0.25
    None
    None

    Other Expenses***
    6.01
    6.01
    6.01

    Total Annual Operating Expenses (%)
    6.91
    6.66
    6.66

    Fee Waiver and/or Expense Reimbursement**
    -5.81
    -5.81
    -5.81

    Total Annual Operating Expenses After Fee Waiver and/or Expense Reimbursement (%)
    1.10
    0.85
    0.85

  * A contingent deferred sales charge of 1.00% may apply on certain redemptions of Class A shares made within 18 months following
a purchase of $1,000,000 or more without an initial sales charge.

 ** First Eagle Investment Management, LLC (“FEIM”) has contractually agreed to waive and/or reimburse certain fees
and expenses of Classes A, I and R6 so that the total annual operating expenses (excluding interest, taxes, brokerage commissions,
acquired fund fees and expenses, dividend and interest expenses relating to short sales, and extraordinary expenses, if any) (“annual operating expenses”)
of each class are limited to 1.10%, 0.85% and 0.85% of average net assets, respectively. Each of these undertakings lasts until
February 28, 2023 and may not be terminated during its term without the consent of the Board of Trustees. The Fund has agreed that
each of Classes A, I and R6 will repay FEIM for fees and expenses waived or reimbursed for the class provided that repayment does
not cause annual operating expenses (after the repayment is taken into account) to exceed either: (1) 1.10%, 0.85% and 0.85% of
the class’ average net assets, respectively; or (2) if applicable, the then-current expense limitations. Any such repayment
must be made within three years after the year in which FEIM incurred the expense.

 *** Other Expenses are based on estimated expenses for the current fiscal year; actual expenses may vary.

Example

The following example is intended to help you
compare the cost of investing in the Real Assets Fund with the cost of investing in other mutual funds. This hypothetical example
assumes you invest $10,000 in the Fund for the time periods indicated and then either redeem or do not redeem all shares at the
end of those periods. The example also assumes the average annual return is 5% and operating expenses remain the same (except that
the fee waiver is taken into account only for the one-year expense example). Please keep in mind your actual costs may be higher
or lower.

    Share Status
    1 Year
    3 Years

    Class A

    Sold or Held
    $607
    $1,945

    Class I

    Sold or Held
    $87
    $1,451

    Class R6

    Sold or Held
    $87
    $1,451

Page 4

 6. COMMENT: With respect to the footnote to the Fees and Expenses table indicated by “**,”
and in particular the sentence “Any such repayment must be made within three years after the year in which FEIM incurred
the expense,” you asked that the phrase “after the year in which FEIM incurred the expense” be revised to “from
the date such amount was initially waived or reimbursed.”

Should the Fund disagree with
the Staff’s comments, you asked that the Fund confirm that FEIM has conducted a FAS 5 analysis and concluded that recoupment
is not probable. In addition, you also asked the Fund to confirm that FEIM has provided the Fund’s auditor with the FAS 5
analysis.

RESPONSE: The Fund respectfully
declines to make the change in response to the Staff’s comment regarding the phrase “after the year in which FEIM incurred
the expense.” The Fund believes that the disclosures are accurate and consistent with the terms of the expense limitation
arrangement in place for the Fund. Under the expense limitation agreement, FEIM has agreed to waive its fees or reimburse the Fund
in order to limit the Fund’s annual operating expenses to the stated expense ratios, as calculated on a per annum basis.

While the Fund will attempt to
estimate the amounts to be waived or reimbursed by FEIM via accruals made throughout the term of the expense limitation arrangement,
the Fund’s expenses and asset levels will fluctuate, preventing a determination of the final annual expense ratios and, accordingly,
the amounts required to be waived or reimbursed by FEIM until the full year is completed. For example, the Fund may experience
a significant increase in asset levels during the term of the expense limitation agreement and may accrue an expense waiver over
the first few months of the term, but later determine that such expense waiver is not actually required if the Fund’s expense
ratio, as calculated on an annualized basis, is under the agreed upon limit. In this situation, despite the fact that the Fund
initially accrued for an expense waiver, FEIM would not actually waive any of its fees during the term.

For this reason, FEIM’s
ability to recoup its previously waived fees or reimbursed expenses cannot be determined until the conclusion of the fiscal year
end. Only if the Funds annual expense ratios are below the agreed upon limits is FEIM eligible for recoupment of its previously
waived fees/reimbursed expenses. Further, under the terms of the expense limitation agreement, such amounts are only eligible for
recoupment if they are within the three years following the year that they were waived or reimbursed. As noted above, the actual
waiver or reimbursement is always determined as of the end of the term. Therefore, any recoupment by FEIM would occur within three
years of that date.

Page 5

At the present time, FEIM has
concluded that it does not believe that the conditions of FAS 5 will require the Fund to record a liability for the potential recapture
of fees waived or expenses reimbursed.

FEIM will provide the Fund’s
independent auditor with its FAS 5 analysis in due course.

PRINCIPAL INVESTMENT STRATEGY AND RISKS

 7. COMMENT: You noted that the second paragraph of the Fund’s Principal Investment
Strategies includes the following disclosure: “Under normal circumstances, the Fund anticipates it will allocate a portion
of its assets to foreign investments (including American Depositary Receipts (‘ADRs’), Global Depositary Receipts (‘GDRs’)
and European Depositary Receipts (‘EDRs’)). The Fund is not required to allocate its investments in any set percentages
to any particular countries, but normally will invest in at least three countries (one of which may be the United States). The
countries in which the Fund may invest may include countries whose economies are still developing (sometimes called ‘emerging
markets’). Typically the Fund will be invested in a number of different countries.”

You asked that the Fund’s Geographic Investment
Risk include similar disclosure.

RESPONSE: The Fund will revise the PEA to address
the Staff’s comment.

 8. COMMENT: You asked the Fund to please consider moving the following disclosure, which
is included in the Fund’s Real Estate Industry Risk, to the Fund’s Principal Investment Strategies section: “The
Fund may invest in securities of companies that focus on real estate related activities. Real estate investment trusts (‘REITs’)
are an example, as are developers and construction businesses, real estate finance companies, real estate brokerages and other
related businesses, such as home improvement and home furnishings retailers. Real estate and its related businesses are highly
dependent on market conditions, including interest rates.”

RESPONSE: The Fund will revise the PEA to address
the Staff’s comment.

 9. COMMENT: You asked the Fund to supplementally explain why Telecommunications, Healthcare,
Automobile and Consumer Staples are included as principal risks if the Fund invests at least 80 percent of its assets in “real
assets.”

You also asked the Fund to include any sectors
or industries that are described in the Principal Risks in the Fund’s Principal Investment Strategies section.

Page 6

RESPONSE: The Fund notes
that it will normally invest at least 80% of its net assets (plus any borrowing for investment purposes) in a variety of assets
believed by the Adviser to represent interests in “real assets” or “real asset” industries. “Specifically,
‘real asset’ industries are those that relate to ownership or production of such assets or products or services otherwise
supporting such assets. These industries may include materials, industrials, chemicals, energy, infrastructure, real estate, and
utilities, as well as related suppliers and similarly connected businesses.”

The Fund will revise its Principal
Investment Strategy to include reference to the telecommunications, communications, healthcare, automobile and consumer staples
sectors or industries as additional examples of “related suppliers and similarly connected businesses.”

 10. COMMENT: With respect the Fund’s Credit and Interest Rate Risk, you asked the Fund
to ensure that the risk corresponds to the instruments described in the Fund’s Principal Investment Strategy. For example,
you noted that high yield instruments are not mentioned in the Principal Investment Strategy.

You also asked the Fund to
include the maturity of the fixed income instruments since the Staff believes the disclosure is unclear that such investments will
be longer duration instruments as suggested by the risk factor.

RESPONSE: The Fund will
revise the PEA to address the Staff’s comment and will include high yield instruments in its Principal Investment Strategy.
The Fund respectfully declines to make any changes to its Credit and Interest Rate Risk since it believes its risk disclosure related
to “duration” and “maturity” generally communicates to a shareholder a debt instrument’s potential
sensitivity to changes in interest rates.

 11. COMMENT: You noted that the only derivatives described in the Principal Investment Strategy
are those held by the Subsidiary. You also noted that such instruments do not appear to be held under a hedging program.

You asked the Fund to please
reconcile the disclosure in the Principal Investment Strategies and Principal Risks sections, and to tailor the Derivatives Risk
to those derivatives identified in the Principal Investment Strategies section.

RESPONSE: The Fund will revise the PEA to address
the Staff’s comment.

 12. COMMENT: You asked whether master limited partnerships (“MLPs”) are a principal
investment and, if so, you asked the Fund to include a description of MLPs in the Principal Investments Strategies section.

Page 7

RESPONSE: The Fund will
revise the PEA to address the Staff’s comment. The Fund notes that MLPs are not a principal investment and, accordingly,
the Fund has removed reference to MLPs as a principal investment, and the associated principal risk, in the PEA.

INVESTMENT RESULTS

 13. COMMENT: You asked the Fund to supplementally identify the broad based index against
which the Fund’s performance will be measured.

RESPONSE: The Fund’s
performance will be measured against the MSCI World Index and the Consumer Price Index for Urban Consumers (CPI-U) plus 400 basis
points.

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