SecProbe.io

CORRESP
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Faegre
Drinker Biddle & Reath LLP

One
Logan Square, Suite 2000

Philadelphia,
PA 19103

Phone:
(215) 988-2700

Fax:
(215) 988-2757

www.faegredrinker.com

May
30, 2023

VIA
EDGAR TRANSMISSION

U.S.
Securities and Exchange Commission

100
F Street, N.E.

Washington,
D.C. 20549

Attention: Mindy
Rotter

 Re: Conestoga
                                         Funds (the “Registrant”) (File Nos. 333-90720; 811-21120)

Dear
Ms. Rotter:

This
letter responds to the staff’s accounting comments that were provided via telephone call on May 3, 2023, on the report to
shareholders of the Conestoga Small Cap Fund (the “Small Cap Fund”), the Conestoga SMid Cap Fund (the “SMid
Cap Fund”), the Conestoga Mid Cap Fund (the “Mid Cap Fund”) and the Conestoga Micro Cap Fund* (the
“Micro Cap Fund,” together with the Small Cap Fund, the SMid Cap Fund and the Mid Cap Fund, the “Funds,”
each a “Fund”) for the fiscal year ended September 30th, 2022.

For
your convenience, we have repeated each comment below in bold, and our responses follow your comments. Capitalized terms not otherwise
defined herein shall have the meaning ascribed to them in the Registration Statement, unless otherwise indicated.

1) The
                                         performance graph for the Micro Cap Fund notes the benchmark is the Russell Microcap
                                         Growth Index. In the prospectus for the Micro Cap Fund, the Fund considers companies
                                         that are “micro cap” to be those companies, that, at the time of initial
                                         purchase (including the existing portfolio) have market capitalizations generally within
                                         the range of companies included in the Russell Microcap Index. Please explain the rationale
                                         for this difference.

The
Fund’s principal investment strategy is to invest at least 80% of its net assets in equity securities of micro-capitalization
companies. In determining whether a stock meets the definition of micro-capitalization, the Fund looks to the Russell Micro Cap
Index, the smallest 1,000 securities in the small-cap Russell 2000 Index, plus the next 1,000 smallest eligible securities by
market capitalization. The Russell Micro Cap Index describes itself in its fact sheet as “constructed to provide a comprehensive
and unbiased barometer for the microcap segment trading on national exchanges.” Because the investment adviser is investing
in microcap stocks where the expected earnings growth exceeds that of the average U.S. publicly traded companies, the performance
of the Fund is compared to that of the growth segment of the Russell Micro Cap Index, the investment adviser believes that the
Russell Micro Cap Growth Index is an appropriate benchmark for measuring the Fund’s performance.

* The
                                         Micro Cap Fund was subsequently renamed the Conestoga Discovery Fund effective April
                                         18, 2023.

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2) Please
                                         explain in correspondence what the borrowing expenses noted in the statements of operations
                                         refers to for all applicable funds.

The
borrowing expenses listed in the statements of operations for the Funds represent overdraft fees that were charged to the Funds
due to late trade settlement.

3) Please
                                         confirm in correspondence that any categories of other expenses in the January 31, 2023
                                         prospectus that exceed 5% of total expenses have been separately identified in accordance
                                         with Regulation S-X 6-07. This comment applies to the Mid Cap Fund and the Micro Cap
                                         Fund.

The
components of expenses that were incurred by the Funds and exceeded 5% of total expenses have been stated separately on the statements
of operations in the September 30, 2022 annual report. The two categories of expenses that exceeded 5% of total expenses for that
reporting period were legal fees and fund accounting fees.

4) Other
                                         accrued expenses on the statements of assets and liabilities (the balance sheets) appear
                                         to be significant. Please confirm in correspondence that any material categories within
                                         other accrued expenses have been stated separately in accordance with Regulation S-X
                                         6-04. This comment applies to the Mid Cap Fund and the Micro Cap Fund.

In
future shareholder reports, the Registrant will break out categories of other accrued expenses that are deemed material in accordance
with Regulation S-X 6-04, which for the September 30, 2022 reporting period represented accrued legal fees and accrued audit fees
for each of the Funds, in the statements of assets and liabilities.

********

We
trust that the foregoing is responsive to your comments. Questions and comments concerning this filing may be directed to the
undersigned at (215) 988-3328, or in my absence, to Joshua Deringer at (215) 988-2959.

    Sincerely,

    /s/ Andrew
    E. Seaberg

    Andrew E. Seaberg

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