SecProbe.io

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  Maria G. Master

  Prudential Investments LLC

  Gateway Center 3

  100 Mulberry Street

  Newark, NJ 07102

  Tel: 973-367-3028 Fax: 973-367-6349

  March 31, 2005

Larry Greene

Office of Disclosure and Review

Division of Investment Management

Securities and Exchange Commission

450 Fifth Street, N.W.

Washington, D.C. 20549

Re:                               Registration Statement on Form N-14 under the Securities Act of 1933
(File No. 333-121795) of Strategic Partners Style Specific Funds/
Strategic Partners Total Return Bond Fund

Ladies and Gentlemen:

Strategic Partners Style Specific Funds (the “Fund”) is writing
in response to comments given by telephone on February 11, 2005, and March 9,
2005, by Larry Greene of the staff (the “staff”) of the Securities and Exchange
Commission (the “Commission”) to the undersigned, regarding the Fund’s
Registration Statement on Form N-14 (File No. 333-121795) under the Securities
Act of 1933, as amended (the “Securities Act”), and the rules and regulations
thereunder. The Fund is currently preparing to file Pre-Effective Amendment No.
1 to the Registration Statement on Form N-14 under the Securities Act, and the
rules and regulations thereunder.

For your convenience, a summary of the staff’s comments is included
herein and the Fund’s responses are keyed accordingly, as follows:

Summary of SEC Comments Received on Strategic Partners Style Specific
Funds/ Total Return Bond Fund N-14 Filing:
12/30/04

General Comments:

Comment:  You noted that the proposed merger is
structured such that the fund with the smaller asset base is the survivor.  Accordingly, you asked that we please confirm
that the Board has considered the factors delineated in North American Security Trust  (SEC No-Action Letter (pub. avail. Aug. 5,
1994) when approving the plan of merger.

Response:  The Commission has stated in the case of North American Security Trust that in
determining whether to use the surviving or non-surviving fund’s portfolio
performance, an accounting, rather than legal, analysis prevails, and
delineated relevant factors for consideration. The Boards of Strategic Partners
Style Specific Funds/Strategic Partners Total Return Bond Fund and Strategic
Partners Mutual Funds, Inc./ Strategic Partners Bond Fund were apprised of and
considered these factors in its decision to approve the merger at the Board
meeting on September 1, 2004.

Comment:  Provide an estimate of the costs of
solicitation.

Response:  The costs of the solicitation are estimated
to be $36,000.

Comment:  Confirm whether the acquired fund will bear
the merger expenses incurred by the acquiring fund, as suggested in the “Dear
Shareholder” letter.

Response:  As indicated in the “Dear Shareholder”
letter, the merger expenses will be shared pro rata by the Funds.

Specific Comments:

Comment Page 4:  Please indicate whether the Funds use
segregated accounts to avoid leverage when employing derivative strategies.

Response:  As indicated in each Fund’s Prospectus and
Statement of Information, when either Fund uses derivative strategies, the Fund
will segregate cash or other liquid assets.

Comment Page 5:  Please revise the sentence describing the
Funds as “diversified” as follows:

“Accordingly, the Bond Fund and the Total
Return Bond Fund are deemed “diversified funds” under the Investment
Company Act of 1940 (the “Investment Company Act”).”

Response:  The sentence will be revised as indicated.

Comment Page 5: Please
clarify the statement regarding the Funds’ fundamental investment restrictions
as follows:

“Each Fund has adopted identical fundamental
investment restrictions, which limit a Fund’s ability to: . . . (vii)
concentrate its investments by investing
25% or more of the value of the Fund’s assets in securities of
issuers having their principal business activities in the same industry.”

Response:  The sentence will be revised as indicated.

Comment Page 6: Please
clarify that foreign markets, economies and political systems, particularly
those in developing countries, may subject foreign investments to increased
risks.

Response: The
sentence will be clarified to indicate the potential for increased risk.

Comment Page 15-17:
For a particular type of fee, where there are no charges for any of the share
classes, you may delete the reference to that fee.

Response:  Where there
are no fees charged, the reference may be deleted.

Comment Page 15-17, 26, 27:  Please specifically state on each applicable
line of the expense charts that expenses projected after the transaction are
pro forma numbers.

Response: The charts
will be so revised.

Comment Page 23:  Under Reasons For The Transaction, in
addition to the factors the Independent Directors considered, please state why
the Funds are merging.

Response: A
described in the section, upon recommendation from the investment managers,
Independent Directors unanimously determined that the transaction would be in
the best interests of shareholders. The reasons for the transaction include
lowing expenses, creating a larger asset base, and allowing shareholders to
participate in the stronger performance of the surviving Fund.

Comment Page 24:  Under Tax Consequences of the Transaction, if
any capital loss carry forwards will be lost as a result of the transaction, so
state.

Response: The SP
Bond Fund does not have any capital loss carry forwards.  Therefore, none will be lost as a result of
the transaction.

Comment Page 28:  Please indicate whether broker nonvotes would
count toward a vote for adjournment.

Response: Broker
nonvotes would count toward a vote for adjournment and will be so noted.

Comment Page 30:
Please confirm that the report of PricewaterhouseCoopers LLP is included in the
Annual Reports to Shareholders for the most recent fiscal year.

Response: With
respect to Strategic Partners Mutual Funds, Inc./ Strategic Partners Bond Fund,
PricewaterhouseCoopers LLP audited the Annual Report to Shareholders for the
fiscal year ending October 31, 2003.
However, this reference will be deleted and will replaced with a
statement indicating that with respect to this Fund, KPMG LLP audited the
Annual Report to Shareholders for the fiscal year ending October 31, 2004.

Pro Forma Statement of Investments:
Please indicate which, if any, investments must be sold as a result of the
transaction. If nothing must be sold, so state as a footnote.  In making these projections, the most recent
fiscal year end should be used as the reference date.

Response: None of
the investments are expected to be sold and a footnote will be added to so
indicate.

Exhibits: Please
confirm that the missing exhibits will be filed.

Response:  As indicated in the Exhibit Index, the
required exhibits are to be filed by subsequent amendment.

The Fund
acknowledges that (i) should the Commission or the staff, acting pursuant to
delegated authority, declare the filing effective, it does not foreclose the
Commission from taking any action with respect to the filing; (ii) the action
of the Commission or the staff, acting pursuant to delegated authority, in
declaring the filing effective, does not relieve the Fund from its full
responsibility for the adequacy and accuracy of the disclosure in the
Registration Statement; and (iii) the Fund may not assert a declaration of
effectiveness as a defense in any proceeding initiated by the Commission or any
person under the federal securities laws of the United States.

Any
questions or comments with respect to the Registration Statement may be communicated
to the undersigned at

973-367-3028.

Please send any
copies of any correspondence relating to this filing to Maria G. Master by
facsimile at 973-367-6349 with the original by mail to Prudential Investments
LLC, 100 Mulberry Street, Newark, New Jersey 07102.

  Very
  truly yours,

  /s/ Maria G. Master

  Maria G. Master

  cc: Larry Greene

  (Securities and Exchange
  Commission)

  Kathryn Quirk

  (Prudential Investments
  LLC)

  Margery K. Neale

  (Shearman & Sterling
  LLP)