SecProbe.io

CORRESP
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  Jonathan D. Shain

  Prudential Investments LLC

  Gateway Center 3

  100 Mulberry Street

  Newark, NJ 07102

  Tel: 973-802-6469  Fax: 973-367-8065

                                                                                                                                                     May 25, 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:                               Strategic
Partners Opportunity Funds — Strategic Partners New Era Growth Fund:  Schedule 14C Information Statement Filing

Ladies and
Gentlemen:

Strategic Partners Style
Opportunity Funds — Strategic Partners New Era Growth Fund (the “Fund”) is writing in response to comments given
by telephone on March 28, 2005, by Larry Greene of the staff (the “staff”) of
the Securities and Exchange Commission (the “Commission”) to the undersigned,
regarding the Fund’s filing on Schedule 14C of preliminary information
statement materials.

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

Comment:  The section of the information statement
entitled “New Subadvisory Agreement” appears to contain an erroneous reference
suggesting that the Fund’s Trustees approved the replacement of TCW Investment
Management Company.

Response:   The reference to TCW Investment Management
Company is erroneous, since the Trustees approved the replacement of Jennison
Associates LLC (Jennison) with TCW Investment Management Company.  We will make the appropriate correction.

Comment:  In the section of the information statement
entitled “Shareholder Proposals,” the information statement should specify
whether or not proposals may be submitted by shareholders without advance
notice at the meeting, or if advance notice is required, then the information
statement should specify the applicable amount of advance notice required.

Response:  We will clarify this section of the
information statement to indicate that shareholders may submit proposals at the
meeting without providing advance notice.

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 proxy
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 proxy
statement may be communicated to the undersigned (973-802-6469).

Please send any copies of any correspondence relating
to this filing to Jonathan D. Shain by facsimile at 973-367-8065 with the
original by mail to Prudential Investments LLC, 100 Mulberry Street, Newark,
New Jersey 07102.

  Very truly
  yours,

  /s/ Jonathan D.
  Shain

  Jonathan D.
  Shain

cc: Larry Greene

(Securities and
Exchange Commission)

Kathryn Quirk

(Prudential
Investments LLC)

Margery K. Neale

(Shearman &
Sterling LLP)