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            Stradley Ronon Stevens & Young, LLP

            2000 K Street, NW, Suite 700

            Washington, DC 20006

            Telephone 202.822.9611

            Fax 202.822.0140

            www.stradley.com

    Christopher J. Zimmerman

    202.419.8402

    czimmerman@stradley.com

    September 30, 2024

    Filed via EDGAR

    Mr. Aaron Brodsky

    U.S. Securities and Exchange Commission

    100 F Street, NE

    Washington, DC 20549

            Re:

            Bridgeway Funds, Inc. (the “Registrant”)

            Registration Statement on Form N-1A

            File Nos.: 033-72416/811-08200

    Dear Mr. Brodsky:

    On behalf of the Registrant, submitted herewith via the EDGAR system are the responses to the comments of the staff (the “Staff”) of the U.S.
      Securities and Exchange Commission (the “Commission”) provided to Christopher J. Zimmerman and Conor Courtney with regard to Post-Effective Amendment Nos. 64 to the Trust’s Registration Statement on Form N-1A (the “Amendment”), which was filed with
      the Commission on July 22, 2024 under the Securities Act of 1933 (the “1933 Act”) and the Investment Company Act of 1940 (the “1940 Act”).  The Amendment was filed to register shares of common stock (“Shares”) in the Global Opportunities Fund (the
      “Fund”), a series of Bridgeway Funds, Inc. (the “Corporation”).  The Staff’s comments are summarized below, followed by the Registrant’s responses thereto.  Terms not defined herein have the meaning set forth for that term in the Amendment.

            1.

            Comment:  The Fund’s name includes the term “global.”  Please expressly describe how the Fund will invest its assets in investments that are tied
              economically to countries around the world (e.g., at least 40% of Fund’s assets) in connection with the Fund’s name. This should be described in the Principal Investment Strategies.

            Response:  The Registrant has revised the Principal Investment Strategies to address this comment as well as other comments made by the Staff, as
              reflected in each response below.  Such revisions requested by the Staff are reflected in both the Item 4 and Item 9 disclosure (unless otherwise noted below).

            Under normal market conditions, the Fund follows a dollar neutral strategy, which the Fund considers
                as a strategy designed to produce a portfolio that is neutral with respect to general stock market direction. The dollar neutral strategy is periodically rebalanced to have roughly equal investments in long and short positions, subject to
                the availability of shorts.  [Note: Item 9 Disclosure Only: To maintain roughly equal investments in
                long and short positions, the Adviser seeks to ensure that the total value of long positions amount to the total value of short positions, when possible.  The Adviser expects to have more long exposure than short exposure on occasions when
                borrowing costs become prohibitive or borrowing availability is poor.] To implement the strategy, the Adviser buys U.S. or foreign (including emerging
                  markets) will invest in equity securities or

              derivatives, the value of which are linked to such securities equity related securities (or derivatives related thereto primarily, equity swaps on individual securities), that, based on a statistical approach, the
                Adviser believes offer an appropriate balance between strong prospects for growth and reasonable valuations relative to their industry peers and sells short securities or enters into short positions on securities that the Adviser identifies
                as overvalued or have weak growth prospects, in amounts that it believes will achieve dollar neutrality.  [Note: Item 9 Disclosure Only: Under this statistical approach, the Adviser intends to buy positions that screen favorably based on valuation metrics, such as earnings to price and sales to price, while simultaneously screening well on metrics
                such as earnings, growth, and price momentum; and short positions with poor financial indicators, such as negative earnings, negative cash flows, and poor price momentum.]

            The Fund will invest in or obtain exposure to issuers located in at least three different countries
                (including the United States) and will invest or obtain exposure of at least 40% of its assets in foreign securities, including companies located in emerging market countries.  Emerging market countries are typically developing and low- or
                middle-income countries, and may be found in regions such as Asia, Latin America, Eastern Europe, the Middle East, and Africa.  The Adviser’s Sstock selection process is applied contextually

                  based on may be applied differently for each country and sector constituency.

            The Fund’s ability to generate positive returns will therefore depend on whether, in a rising market,
                the Fund’s long positions increase in value more than the securities underlying the Fund’s short positions and, in a declining market, whether the securities underlying the Fund’s short positions decrease in value more than the Fund’s long
                positions. By taking long and short positions in different positions equity or equity related securities, the Fund attempts to limit the effect of market movements on portfolio returns. The Fund’s equity exposure may be achieved through investments in individual stocks, exchange traded funds (“ETFs”) and equity swaps on individual securities, which are derivative instruments investments, primarily.  Such derivative instruments are used by the Fund to gain exposure to an underlying asset, which can be more cost-effective than purchasing or selling that asset and provides flexibility in implementing the
                investment strategies of the Fund.  The Adviser anticipates that most of the long and short equity exposure will be through equity swaps on individual securities. Long positions and short positions also may be established using single stock purchases

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            and short sales, swap contracts on single stocks,
              ETFs, and swaps contracts on ETFs traded in
                global equity stock markets. The Fund does this by using a systematic process and may, at any time, buy or sell short any number of positions equity or
                  equity related securities and may have exposure to emphasize specific industries, styles (such as growth or value), capitalization ranges, countries, or other factors.  [Note: Item 9 Disclosure Only: Such other factors that may be observed by the Fund include liquidity, volatility, and debt-to-enterprise value.]

             [Note: Item 9 Disclosure Only: The Adviser’s systematic approach refers to the application in the investment process of a rules-based stock screening process to avoid human emotion in decision making.  The Adviser may override the rules-based
                stock screening process when the Adviser believes the stock price movement is not driven by company financials and forecasts of company financials.  For example, “meme” stocks, companies impacted by government regulations, or companies
                undergoing leadership changes may have price changes that are not related to company financials.

            When the Adviser uses its discretion to override the rules-based stock screening process, the Adviser may adjust its
              “bullish” or “bearish” outlook to neutral views.  The Adviser will rarely take long or short positions in securities that are neither bearish or bullish, except the Adviser may include neutral stocks as part of risk control in the long and
              short portfolios.]

             [Note: Item 9 Disclosure Only: The Fund may take positions in sponsored American Depository Receipts (“ADRs”) as part of its investment strategies.  Sponsored ADRs can become delisted and move to the OTC
                market, so it is possible that Fund holdings may include unsponsored ADRs, although initiating positions in unsponsored ADRs is not part of the Adviser’s process.]

            The overall performance of the Fund depends on the net performance of its long and short positions,
                and it is possible for the Fund to experience a net loss across all positions. If the Fund’s investment strategy is successful, however, the net performance of its long and short positions will produce long-term absolute returns that
                reflects the quality of the Fund’s security selections, which the Fund believes will have with limited
                exposure to general stock market risk.  The Fund’s overall price movements are not expected to correlate with the general stock market’s price movements. In other words, the Fund is expected to have returns that are independent of the
                returns and direction of the general stock market.

            The Adviser’s investment process also incorporates material environmental, social, and governance (“ESG”)
                information, when available, as a consideration in the ongoing assessment of potential portfolio securities. The Adviser uses ESG research and/or ratings information provided by third parties in performing this analysis and considering ESG
                risks. As with any consideration used in assessing portfolio securities, the Adviser may, at times, utilize ESG information to increase the weighting of an issuer with a good ESG record or decrease the weighting of an issuer with a poor ESG
                record. However, as ESG information is just one investment consideration, ESG considerations are not solely determinative in any investment decision made by the Adviser.

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            2.

            Comment:  In connection with the fee waiver and expense reimbursement disclosed in the fee table on page 2, please briefly describe who can
              terminate the arrangement and under what circumstances.

            Response:  The Registrant has revised footnote 3 to the fee table to include the following:

            The Expense Limitation Agreement may be changed or eliminated only with the consent of the Board of Directors of Bridgeway Funds.

            The Registrant separately notes that it has revised the fee table to update “Other Expenses.”  The revised fee table is set forth
              below:

            Shareholder Fees (paid directly from your investment)

            Sales Charge (Load) imposed on Purchases

            None

            Sales Charge (Load) Imposed on Reinvested Dividends

            None

            Redemption Fees (as a percentage of amount redeemed for shares held less than 6 months)

            2.00%

            Exchange Fees

            None

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

            Management Fees

            1.25%

            Distribution and/or Service (12b-1) Fees

            None

            Other Expenses1

            1.63%

                  Acquired Fund Fees and Expenses1, 2

            0.18%

            Total Annual Fund Operating Expenses

            3.06%

            Fee Waiver and/or Expense Reimbursement3

            (1.38%)

            Total Annual Fund Operating Expenses (After Fee Waiver/Expense Reimbursement) 4

            1.68%

            1 Other Expenses and Acquired Fund Fees and Expenses are each estimated for the current fiscal year.

            2 Acquired Fund Fees and Expenses are expenses incurred by the Fund through its ownership of shares in other investment companies, including business development companies.

            3 Bridgeway Capital
                Management, LLC (the “Adviser”), the investment adviser to the Fund is contractually obligated, until at least November 1, 2025, to waive fees and/or pay Fund expenses, if necessary, to ensure that Other Expenses do not exceed 0.25%
                excluding interest, taxes, dividend expense on short sales, interest expense relating to short sales, other borrowing costs, expenses related to class action claims, contingent expenses related to tax reclaim receipts, reorganization
                expenses and extraordinary expenses. The Fund is authorized to reimburse the Adviser for management fees previously waived and/or for expenses previously paid by the Adviser, provided, however, that any reimbursements must be paid at a date
                not more than three years after the Adviser waived the fees or reimbursed the expenses and the reimbursements do not cause the Fund to exceed the expense limitation in effect at the time of the waiver or the current expense limitation, if
                different.  The Expense Limitation Agreement may be changed or eliminated only with the consent of the Board of Directors of Bridgeway Funds.

            4 Total Annual Fund
                Operating Expenses do not correlate to the expense ratio in the Financial Highlights, when available, which reflects operating expenses of the Fund and does not include Acquired Fund Fees and Expenses.

            3.

            Comment:  Please clarify the following terms and disclosure on page 3: (1) “equity related securities,” (2) what it means for “stock selection [to
              be] applied contextually based on country and sector constituency”, and (3) how the Fund defines the terms “emerging markets.”

            Response:  The Registrant has revised the disclosure as reflected in Response 1.

            4.

            Comment:  Please clarify the following terms on page 3 (this may be done in the Item 9 disclosure): (1) “statistical approach” including how the
              “appropriate balance between strong prospects for growth and reasonable valuations” is determined, (2) factors used to assess whether short positions are “overvalued or have weak growth prospects,” and (3) what the phrase “roughly equal
              investments in long and short positions” is referencing.

            Response:  The Registrant has revised the disclosure as reflected in Response 1.

            5.

            Comment:  The Fund has a policy not to concentrate.  Please reconcile this with page 3, which indicates that the Fund may emphasize specific
              industries.

            Response:  The Registrant confirms that the Fund will comply with its fundamental policy not to concentrate in such industries.  The Registrant has
              further revised the disclosure as reflected in Response 1.

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            6.

            Comment:  On page 3, please clarify how single name swaps differs from “equity swaps on individual securities.”

            Response:  These are the same instruments.  The Registrant has revised the disclosure as reflected in Response 1.

            7.

            Comment:  Please specifically disclose the types of derivatives the Fund will use as part of the Principal Investment Strategies.

            Response:  The Registrant has revised the disclosure on page 3 as reflected in Response 1.

            8.

            Comment:  Please describe the purpose that derivatives serve in the Fund (e.g., hedge, speculation) and the extent to which derivatives are
              expected to be used.

            Response:  Registrant has revised the disclosure on page 3 as reflected in Response 1. In addition, Registrant already discloses that the Adviser anticipates that most of the long and short equity exposure will be through equity swaps on individual securities.

            9.

            Comment:  Please define “systematic process” as used on page 3.

            Response:  The Registrant has revised the disclosure as reflected in Response 1.

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