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 CORRESP

 ROPES & GRAY LLP 10250
CONSTELLATION BOULEVARD, 21st FLOOR LOS ANGELES, CA 90067-6257
 WWW.ROPESGRAY.COM

 May 2, 2025

 Jessica Lees

 T +1 310 975 3319

 Jessica.Lees@ropesgray.com
 VIA EDGAR
 Division of Investment Management Securities and Exchange
Commission 100 F Street, NE Washington, DC 20549
 Attn: Ms. Anu Dubey and Mr. Kenneth Ellington

 Re:
 PIMCO Municipal Income Fund II (File No. 333-286391), PIMCO New
York Municipal Income Fund II (File No. 333-286389) and PIMCO California Municipal Income Fund (File No. 333-286388)
 Dear Ms. Dubey, Mr. Ellington: On behalf of PIMCO
Municipal Income Fund II (“ PML ”), PIMCO New York Municipal Income Fund II (“ PNI ”) and PIMCO California Municipal Income Fund (“ PCQ ” and together with PML and PNI, the “ Acquiring
Funds ”), we are writing to provide responses to comments from the staff (the “ Staff ”) of the Securities and Exchange Commission (the “ SEC ”) received from Mr. Ellington via Zoom on April 21, 2025
and from Ms. Dubey via telephone on April 23, 2025 regarding each Acquiring Fund’s Registration Statement on Form N-14 (each, a “ Registration Statement ”), which were
filed with the SEC on April 4, 2025, relating to the following reorganizations:

 •

 PIMCO Municipal Income Fund (“ PMF ”) and PIMCO Municipal Income Fund III (“ PMX ”)
with and into PML;

 •

 PIMCO New York Municipal Income Fund (“ PNF ”) and PIMCO New York Municipal Income Fund III
(“ PYN ”) with and into PNI; and

 •

 PIMCO California Municipal Income Fund III (“ PZC ”) and PIMCO California Municipal Income Fund II
(“ PCK ” and collectively with PMF, PMX, PML, PNF, PYN, PNI, PZC, and PCQ, each, a “ Fund ” and collectively, the “ Funds ”) with and into PCQ.
 Any disclosure changes described in the below responses will be reflected, to the extent applicable, in Pre-Effective
Amendment No. 1 to each Registration Statement. Capitalized terms not otherwise defined herein have the meanings ascribed to them in each Registration Statement.
 The following sets forth the Staff’s comments and the Acquiring Funds’ responses thereto.

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 May 2, 2025
 Accounting Comments

 1.
 Comment : Please confirm that the fees presented in the fee table are still current. See Item 3 of
 N-14. Response : The Acquiring Funds confirm that the fees presented in
the tables under the heading, “Comparison of Fees and Expenses – Total Operating Expenses” in the Registration Statements are current as of December 31, 2024, the Funds’ most recent fiscal year end. More recent fees, for
example as of March 31, 2025, would likely be lower than the currently-presented fees, which include expenses of the auction rate preferred shares (“ ARPS ”) of each Fund. All of the ARPS for these Funds were redeemed during the
Funds’ 2024 fiscal year.

 2.
 Comment : The “as of” date of the tables presented under the heading, “Capitalization of
the Funds,” in the Registration Statements is December 31, 2024. Please confirm that there have been no material changes to the Funds’ balance sheets that should be reflected in the capitalization tables.
 Response : The Acquiring Funds confirm that there have been no material changes to the Funds’ capitalizations (excepting NAV
movements) between December 31, 2024 and the date of this response letter.

 3.
 Comment : The fee tables presented under the heading, “Comparison of Fees and Expenses – Total
Operating Expenses,” in the Registration Statements for certain Funds ( e.g ., PMF, PYN, PZC, PCK and PCQ) do not appear to foot correctly due to rounding. Please revise.
 Response : The Acquiring Funds will make the requested change.

 4.
 Comment : Please consider reordering the Funds under the heading, “Comparison of Fees and Expenses
– Expense Example,” in the Registration Statements for the California Reorganizations to match the order in the fee tables (PZC, PCK and PCQ).
 Response : The Acquiring Funds will make the requested change.

 5.
 Comment : Because the Reorganizations are not contingent on one another, please include the following
information ( See 1995-11 Dear CFO Letter):

 a.
 A pro forma fee table resulting in the highest and lowest combined fees included in the range of possible
outcomes.

 b.
 A pro forma fee table assuming all the Target Funds merge (if this pro forma fee table produces the lowest
possible outcome of combined fees, then only the pro forma fee table resulting in the highest combined fees and the pro forma fee table assuming all Target Funds merge may be disclosed).

 c.
 Accompanying the pro forma fee tables and capitalization tables, a narrative indicating that because completion
of any one Reorganization is not dependent upon completion of any or all of the other Reorganizations, there are combinations of Reorganizations that may occur in addition to those presented.
 Response : Each of the National Reorganizations, New York Reorganizations and California Reorganizations (for purposes of this response,
each a “set” of Reorganizations) are not contingent upon the consummation of any of the other sets of Reorganizations ( e.g. , the National Reorganizations are not contingent upon the consummation of the California Reorganizations and
vice versa).

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 May 2, 2025

However, with respect to each set of Reorganizations, such set of Reorganizations will not move forward to the extent that the common shareholders of the relevant Acquiring Fund do not approve
the National Proposal, the New York Proposal or the California Proposal, respectively. Furthermore, each series of RVMTP Shares is held by a single shareholder, which will be asked to consent to the relevant Reorganizations. Accordingly, there is no
anticipated scenario in which only one (and not both) of the Target Funds in a set of Reorganizations will merge into the corresponding Acquiring Fund.
 As a result, the Acquiring Funds respectfully decline to make this change because adding the requested pro forma disclosures could be confusing
and likely is irrelevant to shareholders.

 6.
 Comment : Disclosure in each Registration Statement states that, “as of the close of business on the
date that the Proposals are approved by shareholders through the Closing Date, the Target Funds will be in a ‘transition period’ during which PIMCO may need to reposition the Target Funds’ assets to prepare to transfer such assets to
the corresponding Acquiring Fund.” Please disclose the following:

 a.
 The estimated percentage of each Target Fund’s portfolio that is expected to be sold in connection with
the Reorganizations.

 b.
 The dollar amount of expected portfolio transaction costs that are expected to be generated as a result of
these trades.

 c.
 The estimated impact to shareholders of capital gains distributions, including the per share amount.
 Response : Please see the response to Comment 18. PIMCO does not currently expect to materially restructure any
Target Fund’s portfolio or reposition its holdings in connection with the Reorganizations in order to align with the corresponding Acquiring Fund’s investment strategies. As a result, no material percentage of each Target Fund’s
portfolio is currently expected to be sold in connection with the Reorganizations and no material corresponding portfolio transaction costs or capital gains distributions are currently anticipated in connection with any such trades. Please see the
three tables regarding estimated portfolio transaction costs under Question 16, “Who will bear the costs associated with the Reorganizations?,” on page xiii of the Questions and Answers section (the “ Q&A ”). Due to
market conditions or other factors that may change between now and the Closing Date, however, the Acquiring Funds believe it is appropriate to keep the referenced disclosure with the changes noted in response to Comment 18.

 7.
 Comment : Please disclose the dollar amount of any capital loss carryforwards that are available for the
Target Funds. Response : The Acquiring Funds will disclose the amount of capital loss carryforwards as of
December 31, 2024, consistent with other financial information included in each Registration Statement. Supplementally, the Acquiring Funds confirm that the amount of capital loss carryforwards for the Funds as of December 31, 2024 is not
materially different than the amount as of March 31, 2025, each as set forth below:

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 May 2, 2025

 Fund Name

 Capital Loss Carryforwards as of 12/31/24

 Capital Loss Carryforwards as of 3/31/25

 PMF

 $
 (33,689,976
 )

 $
 (34,541,179
 )

 PMX

 $
 (40,497,836
 )

 $
 (41,274,593
 )

 PML

 $
 (86,077,994
 )

 $
 (87,978,672
 )

 PNF

 $
 (10,486,526
 )

 $
 (10,884,456
 )

 PYN

 $
 (5,793,450
 )

 $
 (5,972,612
 )

 PNI

 $
 (15,145,920
 )

 $
 (15,457,820
 )

 PZC

 $
 (18,221,605
 )

 $
 (18,797,369
 )

 PCK

 $
 (22,494,317
 )

 $
 (23,200,916
 )

 PCQ

 $
 (20,904,558
 )

 $
 (21,471,439
 )

 8.
 Comment : Please explain supplementally and disclose in the Registration Statements if each
Reorganization will be accounted as an asset acquisition under ASC 805-50.
 Response : The Reorganizations will be accounted for pursuant to the asset acquisition method of accounting under ASC 805-50. The Acquiring Funds will disclose this accordingly.

 9.
 Comment : If any transaction is accounted as an asset acquisition, please disclose if the assets acquired
will be measured as the fair value of consideration transferred or the fair value of assets acquired (NAV) and how such value will be allocated to acquire such assets. Please cite applicable U.S. GAAP and incorporate into the analysis the impact of
the Funds’ traded market prices and discounts / premiums to NAV. Response : Under ASC 805-50-30-2, for asset acquisitions in which the consideration given is not in the form of cash, the consideration is measured based on
either the cost (which shall be measured based on the fair value of the consideration transferred) or the fair value of the assets acquired (NAV), whichever is more clearly evident and, thus, more reliably measurable. The Funds have determined that
the fair value of the assets acquired, as represented by the NAV of the Target Funds, is more clearly evident and, therefore, more reliably measurable. Further, as the Staff is aware, mergers of affiliated
 closed-end funds are typically effected pursuant to the respective NAVs of the relevant funds to avoid shareholder dilution concerns. The NAV will be calculated in accordance with the valuation procedures
adopted by the Board of each Fund as described further in the section, “Net Asset Value,” in the Registration Statements. The Acquiring Funds will disclose this accordingly.

 10.
 Comment : Please explain supplementally if any day one unrealized gains / losses will result from the
acquisitions post-Reorganizations. Please cite applicable U.S. GAAP. Response : Under ASC 805-50-30-3, the cost of a group of assets acquired in an asset acquisition is allocated to individual assets acquired or
liabilities assumed based on their relative fair values and does not give rise to goodwill. For financial reporting purposes, the historical cost basis of the investments received from each Target Fund will be carried forward to align ongoing
reporting of the realized and unrealized gains and losses of each Acquiring Fund with amounts distributable to shareholders for tax purposes. Accordingly, no day-one gain or loss is anticipated as a result of
the acquisitions post-Reorganizations.

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 May 2, 2025

 11.
 Comment : Please explain how disclosure requirements of Items 5(b) and 6(a) of Form N-14 have been met, specifically related to ten years of financial highlights and ten years of senior securities information.
 Response : The Acquiring Funds will revise the relevant disclosure to include this information.

 12.
 Comment : Please include hyperlinks to the documents that are incorporated by reference on page iv of the
Proxy Statement/Prospectus. Response : The Acquiring Funds will make the requested change.

 13.
 Comment : Please confirm in correspondence and disclose in each Registration Statement that each
Acquiring Fund will be the accounting survivor of the corresponding Reorganization and provide supplementally the relevant analysis for each Reorganization under the no-action letter provided to North American
Security Trust (“ NAST ”). See North American Security Trust, SEC No-Action Letter (pub. avail. August 5, 1994).
 Response : The Acquiring Funds will make the requested change. The draft NAST accounting survivor analysis for the Reorganizations is set
forth in Exhibit A hereto. Disclosure Comments

 14.
 Comment : The “Dear Shareholder Letter” states that, “[s]eparately, the holders of the
RVMTP Shares of each Target Fund will be asked to consent to the applicable Reorganization, and the consummation of a Reorganization with respect to each such Target Fund will be contingent on the consent of the holders of its RVMTP Shares, as
applicable.” Were RVMTP Shares issued in an offering that was registered under the Securities Act of 1933, as amended? If so, are they eligible for resale under Rule 144A? Will any filing be made in connection with obtaining the consent of
RVMTP shareholders and the exchange of RVMTP Shares ( e.g ., a separate N-14 8C or proxy filings)? If not, please supplementally explain why there will be no N-14
or proxy filings with respect to the RVMTPs. Response : Each series of RVMTP Shares issued by the Funds was
originally issued and sold to investors in an offering exempt from the registration requirements under the Securities Act. Each series of RVMTP Shares may not be offered, sold or otherwise transferred except in compliance with the registration
requirements of the Securities Act or under Rule 144A of the Securities Act. In connection with the Reorganizations, holders of the RVMTP Shares will receive newly issued RVMTP Shares of the Acquiring Funds pursuant to a private exchange offer. The
holders are being presented information regarding the private exchange offer for purposes of obtaining their consent, which information will include the Registration Statement for informational purposes. As such, no filings with the SEC are
currently planned or required in connection with obtaining the consent of RVMTP shareholders and the exchange of RVMTP Shares.

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 May 2, 2025

 15.
 Comment : Please disclose whether any Fund, its investment manager, or any of the Fund’s affiliates
have entered into a standstill agreement with respect to the Fund and a third-party. If so, provide a copy of such agreement or tell us where it is filed. It is our intention to review any such agreement, and we may have additional comments after
doing so. For purposes of this comment, a standstill agreement is an agreement whereby a third party agrees to take (or not take) one or more specified action(s) with respect to a Fund.
 Response : The Acquiring Funds confirm that no Fund, PIMCO or, to the best of PIMCO’s knowledge, any affiliated person of a Fund,
has entered into a standstill agreement with respect to a Fund.

 16.
 Comment : In the first set of bullets under Question 3, “What is the rationale for the
Reorganizations?,” on page iv of the Q&A, please also disclose that PML’s total annual expenses will increase after the National Reorganizations.
 Response : The Acquiring Funds will revise the three bullets as follows:

 •

 With respect to the National Reorganizations, the contractual management fee rate of PML is lower than
contractual management fee rates paid by each National Target Fund. The pro forma total annual operating expenses of the combined Acquiring Fund are expected to
increase relative to those of PML (the Acquiring Fund) and decrease relative to those of each National Target Fund. Any increase is primarily due to differences in leverage among the Funds ;

 •

 With respect to the New York Reorganizations, the contractual management fee rate of PNI is