SecProbe.io

<DOCUMENT>
<TYPE>CORRESP
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>
KIRKPATRICK & LOCKHART NICHOLSON GRAHAM LLP     1800 Massachusetts Avenue, N.W.
                                                Suite 200
                                                Washington, DC  20036-1221
                                                202.778.9000
                                                Fax 202.778.9100
                                                www.klng.com

                                 June 27, 2005

VIA EDGAR
---------

Mr. Chad Eskildsen
Securities and Exchange Commission
450 Fifth Street, NW
Washington, DC  20549-0506

         Re:      LKCM Funds (the "Trust")
                    Post-Effective Amendment No. 21
                    (FILE NOS. 033-75116 AND 811-8352)
                 ------------------------------------

Dear Mr. Eskildsen:

         The  following  are  the  Trust's  responses  to the  comments  that we
received  from  you  by  telephone  on  May  25,  2005   regarding  the  Trust's
Post-Effective  Amendment  No.  21  (the  "Post-Effective   Amendment")  to  the
Registration  Statement on Form N-1A. The Post-Effective  Amendment was filed on
April 15, 2005. Your comment and the Trust's response are found below.

         The Trust acknowledges that: (1) it is responsible for the adequacy and
accuracy of the disclosure in its registration statement;  (2) staff comments or
changes  to  disclosure  in  response  to  staff  comments  in the  registration
statement  reviewed by the staff do not  foreclose the  Securities  and Exchange
Commission  ("SEC")  from  taking any action  with  respect to its  registration
statement;  and  (3) it may  not  assert  staff  comments  as a  defense  in any
proceeding  initiated by the SEC or any person under the federal securities laws
of the United States.

PROSPECTUS
----------

         1.   COMMENT:  You requested that the Item 2 disclosure include a brief
              discussion related to socially responsible investing.

              RESPONSE: The Trust has included disclosure related to each Fund's
              practice of  investing  in socially  responsible  investing in the
              introductory paragraph in the "Risk/Return Summary" section.

         2.   COMMENT:  You  requested  that the Trust  clarify  which Funds are
              subject  to the  risks  of  value  investing  in the  "Risk/Return
              Summary" section.

<PAGE>

KIRKPATRICK & LOCKHART NICHOLSON GRAHAM LLP

Mr. Chad Eskildsen
June 27, 2005
Page 2

              RESPONSE:  Since only the LKCM Aquinas  Value Fund has a principal
              strategy of  investing in value  securities,  it is subject to the
              risks of value  investing.  The Trust has clarified the disclosure
              in the prospectus accordingly.

         3.   COMMENT: You requested that the Trust revise the disclosure in the
              "Past  Performance"  section  considering the Funds will adopt the
              financial highlights of the existing Aquinas Funds.

              RESPONSE:  The Trust has revised the  disclosure  to indicate that
              each Fund began  offering its shares on July 11,  2005,  and thus,
              does not have any prior  performance  history of its own. Further,
              the Trust has  disclosed  that each Fund has adopted the financial
              highlights of a predecessor fund, which may be found at the end of
              the Prospectus.

         4.   COMMENT:  You  requested  that the  Trust  supplementally  explain
              whether the Trust's investment  adviser (the "Adviser")  satisfies
              the conditions of Instruction 11 to Item 22(b)(7) of Form N-1A.

              RESPONSE:  The  Adviser has  informed  the Trust that it meets the
              conditions   enumerated  in  the  above   mentioned   Instruction.
              Specifically,  neither the Adviser  nor any of its  affiliates  is
              currently or has been in control (as defined in Section 2(a)(9) of
              the Investment Company Act of 1940) of the previous adviser to the
              predecessor  funds.  Further,  the  Adviser  does not  employ  any
              officer or employee of the previous  adviser who were  responsible
              for providing investment advisory or portfolio management services
              to the old funds.  Lastly,  the Trust  notes that it will  include
              disclosure  accompanying  the performance  graph (when included in
              the  Prospectus)  explaining  that  prior  periods  managed by the
              previous adviser are not shown.

         5.   COMMENT:   You  requested  that  the  Trust  clarify  whether  the
              portfolio  managers share the  day-to-day  management of the Funds
              equally, or if there are more specific roles for each manager.

              RESPONSE: The Trust confirms that the portfolio managers share the
              day-to-day management of the Funds equally.

         6.   COMMENT:  You  requested  that the Trust  present the  information
              relating to portfolio managers on a fund specific basis.

                                      -2-

<PAGE>

KIRKPATRICK & LOCKHART NICHOLSON GRAHAM LLP

Mr. Chad Eskildsen
June 27, 2005
Page 3

              RESPONSE:  The Trust notes that the  disclosure for each portfolio
              manager  specifies  the name of  those  Funds  that the  portfolio
              manager  has  day-to-day  responsibility.  Accordingly,  the Trust
              believes the current  disclosure  meets the  requirements  of Form
              N-1A.

         7.   COMMENT:  You  requested  that the Trust  clarify when it will use
              fair value pricing.

              RESPONSE:  The Trust has revised the  disclosure in the "Valuation
              of  Shares"  section  to  indicate  that the Trust will fair value
              securities  if in  the  opinion  of the  Adviser  such  action  is
              warranted.

         8.   COMMENT:  You  requested  that the  Trust  include  the  financial
              highlights of the predecessor funds.

              RESPONSE:  The Trust will include the financial  highlights in the
              Trust's Post-Effective Amendment pursuant to Rule 485(b) under the
              Securities  Act of 1933,  which is  expected  to occur  later this
              month.

         9.   COMMENT:  You requested  that the Trust include  disclosure on the
              back  cover  of  the   Prospectus   relating  to  the  annual  and
              semi-annual  reports of the Funds as required by Item 1(b) of Form
              N-1A.

              RESPONSE:  The Trust has included the disclosure  required by this
              Item.

                                   * * * * *

         If you have any questions regarding the matters discussed above, please
feel free to call me at (202) 778-9187.

                                         Sincerely,

                                         /s/ Francine J. Rosenberger
                                         ------------------------------
                                         Francine J. Rosenberger

cc:      Jacqui Brownfield
            Luther King Capital Management Corporation

                                      -3-
</TEXT>
</DOCUMENT>