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April 19, 2024

VIA EDGAR

United States Securities and Exchange Commission

Division of Investment Management

100 F Street, N.E.

Washington, D.C. 20549

Attn: Kim McManus

    Re:
    Post-Effective Amendment No. 146 to the Registration Statement on
    Form N-1A of Driehaus Mutual Funds (“Trust”) with regard to the Driehaus International Developed Equity Fund (“Fund”)

    (Reg. Nos. 333-05265; 811-07655)

Dear Ms. McManus,

This letter is submitted on
behalf of the Fund in response to comments of the Staff of the Securities and Exchange Commission (“SEC”), received on March
27, 2024, regarding the above-referenced Post-Effective Amendment (“Amendment”). The Amendment was filed on behalf of the
Fund on February 15, 2024 with an effective date of April 30, 2024.

The Staff’s comments are
restated below, followed by the Fund’s responses.

 1. Comment: For the Item 3
                                            fee table, consider if there should be a line item in the fee table for acquired fund fees
                                            and expenses (“AFFE”).

Response: While the Fund may invest
in other funds, such as money market funds, it is not currently expected that the Fund will do so in amounts sufficient to warrant inclusion
of AFFE in the fee table.

 2. Comment: The Fund’s
                                            “Principal Investment Strategies” section states that the Fund invests at least
                                            80% of its net assets (plus the amount of borrowings for investment purposes) in equity securities
                                            issued by non-U.S. developed market companies of all market-capitalizations. Please specify
                                            what securities, if any, fall into the remaining 20%.

Response: The Fund has further specified
in the referenced disclosure that “the Fund may also, from time to time, invest up to a maximum of 20% of its assets in the equity
securities of U.S. companies and/or non-developed market companies.”

 3. Comment: In the second
                                            sentence of the Fund’s “Principal Investment Strategies” section, please
                                            clarify that the fund “will invest” or “invests” in equity securities
                                            of non-U.S. developed market countries.”

Response: The Fund has clarified
this sentence to state that it “will invest” in equity securities of non-U.S. developed market countries.

 4. Comment: In the second
                                            sentence of the Fund’s “Principal Investment Strategies” section, please
                                            clarify that for purposes of the Fund’s 80% investment policy, equity securities include
                                            preferred shares, convertible debt securities and derivatives.

Response: Preferred shares may be
included in the Fund’s 80% investment policy, but they are not a principal investment strategy of the Fund. The Fund has included
a reference to this security type under “Investment Objective and Principal Investment Strategies” for the purpose of defining
types of equity securities.

 5. Comment: Under the Fund’s
                                            “Principal Risks” section, please include a derivatives and/or options related
                                            risk, or explain why such instruments do not present a material risk to the Fund.

Response: It is not anticipated
that the Fund will invest in derivatives or options; accordingly, derivatives and options-related risk has not been included.

 6. Comment: The Fund’s
                                            “Foreign Securities and Currencies Risk” makes mention of emerging market risk.
                                            Please provide the Fund’s definition of emerging markets if emerging markets are a
                                            principal risk of the Fund.

Response: Emerging markets will
not be principal to the Fund’s investment strategy; accordingly, a definition of emerging markets has not been added. Furthermore,
the “Foreign Securities and Currencies Risk” language has been modified to remove a reference to emerging markets.

 7. Comment: Under the “Investment
                                            Objective and Principal Investment Strategies” section, it states that the equity securities
                                            the Fund invests in includes convertible debt securities. Please confirm that the Fund may
                                            include convertible debt securities in the Fund’s 80% equity securities policy, if
                                            such convertible debt securities are “in the money” or were “in the money”
                                            when purchased.

Response: It is not anticipated
that the Fund will invest in convertible debt securities; accordingly the reference has been removed from the prospectus

 8. Comment: Under the “Investment
                                            Objective and Principal Investment Strategies” section, regarding the Fund’s
                                            ESG statement:

 a. Please disclose, if accurate, that an
                                            investment could be made in an issuer that scores poorly on ESG factors, if such investment
                                            performs strongly on other factors considered.

 b. Please include an ESG risk disclosure,
                                            or explain why ESG risk is not material to the Fund.

Response: The Fund has revised the
Fund’s ESG statement in response to (a) to state that an investment could be made in an issuer that scores poorly on ESG factors,
if such investment performs strongly on other factors considered and will revise the disclosure in “Manager Risk” to disclose
that, “in making security selections (including ESG factors relevant to a security), the investment adviser relies on data that
may be incomplete, inaccurate or unavailable, which can adversely affect the analysis of a particular investment.”

 9. Comment: Under the “Investment
                                            Objective and Principal Investment Strategies” section, please confirm, and revise
                                            to clarify, that the Fund will limit derivative exposure to 10% of net assets.

Response: The Fund confirms this
and disclosure that the Fund will limit derivatives exposure to 10% of net assets has been added to the prospectus.

 10. Comment: Under the “Investment
                                            Restrictions” section of the Fund’s statement of additional information, pursuant
                                            to Item 16 of Form N-1A and Section 8(b)(1) of the Investment Company Act of 1940, as amended
                                            (the “1940 Act”), please revise the fifth (5) Investment Restriction to read
                                            (in part):

(5) invest in a security if 25% or more
of its net assets (taken at market value at the time of a particular purchase) would be invested in the securities of issuers in any
particular industry or group of industries…

Response: The Fund respectfully
declines to make any changes to its fifth Investment Restriction. The Fund believes that the industry concentration policy, as set forth
in the SAI, is consistent with Section 8(b)(1)(E) of the 1940 Act, Instruction 4 to Item 9(b)(1) and Item 16(c)(iv) of Form N-1A, which
provide that a fund must disclose its policy with respect to concentrating investments in a particular industry or group of industries.
The Fund does not have a policy to concentrate its investments in any particular industry or group of industries. Rather, the
Fund’s industry concentration policy, states that the Fund will not concentrate its investments in “any particular
industry.” Neither Section 8(b)(1)(E) of the 1940 Act nor Form N-1A, require the Fund to disclose a policy not to concentrate its
investments with respect to both industries and groups of industries. We submit that the use of the term “or”
in this context indicates that a fund must have a concentration policy with respect to particular industries or groups of industries.
In addition, our research indicates that the industry concentration policy for the Fund is consistent with industry concentration policies
of other fund complexes. Further, defining “groups of industries” for a non-concentrated fund would be extremely challenging
because there are so many different combinations of industries that would need to be monitored.

The distinction between policies to concentrate
“in a particular industry or group of industries” from policies to not concentrate “in any particular industry”
is consistent with prior SEC guidance.1 Guide 19 states:

“It is the position of the staff
that investment (including holdings of debt securities) of more than 25 percent of the value of the registrant’s assets in
any one industry represents concentration. If the registrant intends to concentrate in a particular industry or group of
industries it should…specify in the prospectus the industry or group of industries in which it will concentrate.…If
the registrant does not intend to concentrate, no further investment may be made in any given industry if, upon making the proposed investment,
25 percent or more of the value of the registrant’s assets would be invested in such industry” (emphasis added).

1
Registration Form Used by Open-End Management Investment Companies, SEC Rel. No. IC-13436 at Guide 19 (Aug. 12, 1983) (“Guide 19”).

If you have any questions regarding any of the foregoing
or require additional information, please reach me at (312) 609-7616 or rhardt@vedderprice.com.

    Sincerely yours,

    /s/ Renee M.
    Hardt

    Renee M. Hardt

    Shareholder

    Vedder Price P. C.

cc: Christina Algozine