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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

    October 11, 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 supplemental comments of the staff (the “Staff”) of
      the U.S. Securities and Exchange Commission (the “Commission”) provided to Prufesh R. Modhera and Christopher J. Zimmerman on October 4, 2024 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 provided initial comments regarding the Amendment to the Registrant on September 4, 2024, and the Registrant addressed the Staff’s initial
      comments in a response letter (the “Response Letter”) filed with the Commission on October 4, 2024.  The Staff’s supplemental 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:  In response to Prior Response 1 regarding the use of
              “global” within the fund’s name, please specify the criteria that the Fund will use to determine whether a company is “global” (i.e., the location, etc.).

            Response:  Registrant has defined “global” to include “foreign
              securities.”  Foreign securities are disclosed in the Item 9 required disclosure: “For purposes of the Fund’s investments, “foreign securities” means those
                securities issued by companies: (i) that are domiciled in a country other than the US; and (ii) that derive 50% or more of their total revenue from activities outside of the US.”  In response to the SEC Staff’s comment, Registrant
              will also include such criteria in the Item 4 required disclosure.

            2.

            Comment:  In the Item 9 revised disclosure, please clarify the nature
              of “risk control” in the sentence, “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.”  Is risk control referring to risk within the strategy or a different type of risk?

            Response:  Risk control is referring to risk management within the
              strategy.  Registrant has revised the statement as follows:

            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 its risk control management strategy in the long and short portfolios.

            3.

            Comment:  In the Item 9 revised disclosure, please disclose whether
              the Adviser’s belief that the stock price movement is not driven by company financials and forecasts of company financials is the only instance where the Adviser may override the rule-based stock screening process.

            Response:  Registrant confirms that this is the only instance and has
              revised the statement as follows:

            The Adviser may override the rules-based stock screening process only when the Adviser believes the stock price movement is not driven by company financials and forecasts of company financials.

            4.

            Comment:  In the fees and expenses table, please confirm
              supplementally whether the reduction of gross expenses will be for at least one year after the date of the prospectus.

            Response:  Registrant confirms that gross expenses will be reduced for
              at least one year after the date of the prospectus.

            5.

            Comment:  In response to Prior Response 21, please confirm whether any
              such charitable contributions will be made in the current fiscal year.

            Response:  The Adviser anticipates that it will make charitable
              contributions in the current fiscal year.

            6.

            Comment:  In response to Prior Response 21, please disclose the
              circumstances the Adviser may terminate its charitable obligations (emphasis added).

            Response:  The Registrant has revised the following sentence: “While
              the Adviser may terminate or change the level of its
              donations in the future, it does not have any current intention to do so.”

    Please do not hesitate to contact me at the above-referenced telephone number if you have any questions or wish to discuss any of
      the above responses presented above.

            Sincerely,

            /s/ Christopher J. Zimmerman

            Christopher J. Zimmerman

            cc:

            Deborah L. Hanna,

            Treasurer, Principal Financial Officer, and Principal Accounting Officer

            Prufesh R. Modhera, Esq.

            Conor Courtney, Esq.

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