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. 333-121797) of Strategic Partners Style Specific Funds/
Strategic Partners Small Capitalization Value Fund

Ladies and Gentlemen:

Strategic Partners Style Specific Funds 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. 333-121797) 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:

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Summary of SEC Comments Received on Strategic Partners Style Specific
Funds/Small Capitalization Value 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 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 has
delineated relevant factors for consideration. The Boards of Strategic Partners
Style Specific Funds/Strategic Partners Small Capitalization Value Fund and
Strategic Partners Mutual Funds, Inc./ Strategic Partners Small Company Fund
(each a “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 solicitation are estimated at $40,000.

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.

Comment:  Please include disclosure required by Rel. No.
33-8458, Disclosure Regarding Portfolio
Managers of Registered Management Investment Companies and Rel. No.
33-8408, Disclosure
Regarding Market Timing and Selective Disclosure of Portfolio Holding,as applicable.

Proposed Response: The appropriate disclosure will be added.

Specific Comments:

Comment Page 4:  Please define “except as permitted by the 40
Act,” with respect to the Fund’s ability to issue senior securities, borrow
money or pledge assets.

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Response:  The Registration Statement will be amended to
indicate that, under the Investment Company Act of 1940, as amended, a Fund can
borrow money from a bank provided that immediately after such borrowing there
is asset coverage of at least 300% for all borrowings.  If the asset coverage falls below 300%, the
Fund must, within three business days, reduce the amount of its borrowings to
satisfy the 300% requirement.

Comment Page 5:  Please indicate whether “foreign money market
instruments” includes those of emerging market countries.

Response:  Yes, the Fund may invest in money market
instruments from emerging market countries and the disclosure will be clarified.

Comment Page 5:
Please confirm that we have an Order from the Commission with respect to
investing in money market mutual funds managed by the Fund’s sub-adviser.

Response: As
disclosed in each Fund’s Statement of Additional Information, each Fund may
invest up to 25% of its total assets in shares of an affiliated mutual fund, as
permitted under an Order from the Commission.

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 more than 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 12:
Please indicate which Fund NFJ Investment Group (“NFJ”) sub-advises in the
sentence discussing the portfolio management team.

Response: As
indicated under the section “Management of the Company and the Funds,” NFJ
is a sub-adviser for the Small Capitalization Value Fund.

Comment Page 15:
Consolidate the footnotes to the Comparative Fee Tables and move them to the
end of the tables.

Response: The tables
will be so modified.

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

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

Comment Page 16:  The footnote indicates that Class B shares
convert to Class A shares approximately seven years after purchase.  Please define “approximately.”

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Response:  As disclosed in each Fund’s Prospectus and
Statement of Additional Information, Class B shares will automatically convert
to Class A shares on a quarterly basis approximately seven years after
purchase.  Some variability in
calculating the precise time period may occur depending on when and how the
Class B shares were acquired.  In the
case of Class B shares acquired through the reinvestment of dividends or
distributions, the broker —dealer through which the Class B shares where
purchased may employ varying procedures for calculating the applicable holding
period for conversions.  Furthermore, the
last day of the month is generally used to calculate the holding period for
Class B shares acquired through purchases, an exchange, or a series of
exchanges.   For Class B shares previously
exchanged for shares of Special Money Market Fund, Inc., the time period during
which such shares were held in that money market fund will be excluded, and the
exchanges will be deemed to have been made on the last day of the month.

Comment Page 16:  Please confirm whether any expense waivers in
the chart are voluntary.

Response: The fees
listed in the expense tables include only contractual waivers.

Comment Page 16-20, 26, 27:  Please specifically state on each applicable
line that expenses projected after the transaction are pro forma numbers.

Response: The charts
will be so revised.

Comment Page 23:  Under the section “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 25:  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 Small Company 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 31:
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 Small Company 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.

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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)

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