Correspondence 0001999371-24-003600 from ARTISAN PARTNERS FUNDS INC (CIK 0000935015)
ARTISAN PARTNERS FUNDS INC (CIK 0000935015)
Date: March 15, 2024 · CIK: 0000935015 · Accession: 0001999371-24-003600
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File numbers found in text: 811-8932
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CORRESP
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Simpson Thacher & Bartlett
LLP
900 G Street, NW
Washington,
D.C. 20001
telephone:
+1-202-636-5500
facsimile:
+1-202-636-5502
Direct Dial Number
(202) 636-5915
E-mail Address
nathan.briggs@stblaw.com
March 15, 2024
VIA EDGAR
U.S. Securities and Exchange Commission
Division of Investment Management, Disclosure Review Office
100 F Street, N.E.
Washington, D.C. 20549
Attention: Deborah L. O’Neal
Re: Artisan Partners Funds, Inc. (Registration Nos. 33-88316 and 811-8932); Responses to Comments on Preliminary Proxy Statement
Dear Ms. O’Neal:
I am writing on behalf of
Artisan Partners Funds, Inc. (“Artisan Partners Funds”) to respond to the comments by the staff (the “Staff”)
of the U.S. Securities and Exchange Commission (the “Commission”) on Artisan Partners Funds’ preliminary proxy statement
in respect of Artisan International Explorer Fund, a series of Artisan Partners Funds (the “Fund”), which was filed on Schedule
14A with the Commission on February 26, 2024 (the “Preliminary Proxy Statement”). A comment regarding the Preliminary Proxy
Statement was delivered by the Staff via telephone on March 5, 2024. The comment and Artisan Partners Funds’ response are set forth
below. Changes noted below will be reflected in the definitive proxy statement, which will be filed on or around the date hereof.
Questions
and Answers
1. Comment: Please revise the answer in the section of the Notice of Special Meeting of Shareholders
titled “Questions and Answers—Why are shareholder being asked to approve these changes?” to include a brief discussion
of the potential risks associated with the Fund being reclassified as a “non-diversified” fund.
Response: In
response to the Staff’s comment, the Fund has revised the aforementioned section as follows (additions denoted by underline):
Securities and Exchange Commission
March 15, 2024
Q. Why are shareholders
being asked to approve these changes?
A. As explained more
fully in the Proxy Statement, the Reclassification is proposed, among other reasons, to allow the Fund more flexibility in achieving its
investment objective. Based on its experience and investment analysis, Artisan Partners Limited Partnership (“Artisan Partners”),
the Fund’s investment adviser, believes that the Reclassification could potentially enable the Fund to achieve stronger absolute
and relative performance over the long-term by providing the Fund with this additional flexibility. The Reclassification will allow Artisan
Partners the potential to seek to maximize the impact of its investment theses in respect of those companies in which it has the highest
conviction. For example, managing the Fund as a “non-diversified” fund would allow the Fund’s investment team to manage
its portfolio, which consists primarily of stocks of non-U.S. small-capitalization companies, with reduced portfolio turnover. Maintaining
the Fund as a “diversified” fund is expected to increasingly limit the Fund’s investment flexibility within the non-U.S.
small-capitalization universe as represented by the MSCI All Country World ex USA Small Cap Index. Accordingly, to enhance the
Fund’s ability to pursue attractive The increased investment flexibility
to invest a larger portion of its assets in securities of a smaller number of issuers than a diversified fund may, however, make the Fund
more susceptible to economic, business political or other factors affecting the particular issuers in which it invests because larger
investments in individual companies will have a greater effect on the Fund’s performance.
In consideration
of the foregoing, including the potential to enhance the Fund’s ability to pursue attractive investment opportunities and increase
the degree of investment freedom for the Fund, the Board is proposing that Shareholders approve the Reclassification.
* * * * * * * *
Please do not hesitate to call me at (202) 636-5915
or Benjamin J.G. Ruano at (202) 636-5548 with any questions or further comments regarding this submission.
Very truly yours,
/s/ Nathan Briggs
Nathan Briggs
cc:
Laura E. Simpson, Esq., Artisan Partners Limited Partnership
Young Kyung Lee, Esq., Artisan Partners Limited Partnership
Benjamin J.G. Ruano,
Esq., Simpson Thacher & Bartlett LLP