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August 16, 2021

VIA EDGAR

Ms. Anu Dubey

Division of Investment Management

Securities and Exchange Commission

100 F Street, N.E.

Washington, DC 20549

Mr. Ken Ellington

Division of Investment Management

Securities and Exchange Commission

100 F Street, N.E.

Washington, DC 20549

Re: Aberdeen Funds (the “Registrant”)

  The Proxy Statement/Prospectus Filed on July 23, 2021

  Securities
Act File No. 333-258150

Dear Ms. Dubey and Mr. Ellington:

This letter responds to comments on the above-referenced Proxy Statement/Prospectus
filed on Form N-14 with respect to the proposed reorganization of the Aberdeen International Sustainable Leaders Fund, Aberdeen Global
Equity Impact Fund and Aberdeen Global High Income Fund (each a “Target Fund”), each a series of Aberdeen Investment Funds,
into corresponding series of Aberdeen Funds of the same name (each an “Acquiring Fund”) that the staff (the “Staff”)
of the Securities and Exchange Commission (the “SEC”) provided in telephone conversations with Megan Johnson of Dechert LLP
on August 4, 2021, and Brooke Clark and Louis Rosenbaum of Dechert LLP on July 27, 2021.

For your convenience, the substance of those comments has been restated
below. The Registrant’s response to each comment is set out under the restated comment.  Defined terms, unless otherwise
defined herein, have the meanings given them in the Proxy Statement/Prospectus.

Comment
No. 1:               Please supplementally confirm that the fees in each fees and expenses
table are the current fees of the Funds. Please see Item 3 of Form N-14.

Response:                         The
Registrant will update the fees in each fees and expenses table to reflect annualized fees and expenses as of the Funds’ semi-annual
period ended April 30, 2021.

Comment
No. 2:               Please supplementally confirm that
any expenses of a Target Fund subject to recoupment will not be subject to recoupment after the Reorganizations.

Response:                         See
response to Comment No. 11 below.

Comment
No. 3:               In the “What are the federal
income tax consequences of each Reorganization?” section, please disclose the dollar amount and the related expiration dates of
any capital loss carryforwards that are available for each Target Fund and discuss any potential loss or limit on the use of those capital
loss carryforwards as a result of each Reorganization.

Response:                         The
Registrant has added the following:

As of October 31, 2020, capital
loss carryforwards, as shown in the table below, were available to the Target Funds to the extent provided by the regulations to offset
future realized gains on each respective fund as indicated. Each Reorganization is not expected to result in limitations on each Acquiring
Fund’s ability to use each Target Fund’s capital loss carryforwards.

    Fund
    Amount
    Expires

    Select International Equity Fund
    $ 20,177,122
    Unlimited (Short-Term)

    Select International Equity Fund
      407,098,101
    Unlimited (Long-Term)

    Global Equity Impact Fund
      24,240,219
    Unlimited (Long-Term)

    Global High Income Fund
      53,728,063
    Unlimited (Short-Term)

    Global High Income Fund
      184,203,495
    Unlimited (Long-Term)

Comment
No. 4:               Please supplementally confirm and disclose
that each Target Fund will be the accounting survivor of each applicable Reorganization.

Response:                         The
Registrant confirms that each Target Fund will be the accounting survivor of each applicable Reorganization and will add a statement to
that effect to the Prospectus/Proxy Statement.

Comment
No. 5:               Please represent that none of the newly
organized Acquiring Funds will publicly offer or sell shares until each applicable Reorganization is approved by shareholders.

Response:                         The
Registrant confirms that the Acquiring Funds will not publicly offer or sell shares until each applicable Reorganization has been approved
by shareholders.

Comment
No. 6:               In the “What effect will each Reorganization
have on me as a Target Fund shareholder?” section, please clarify whether the portfolio managers will continue to be the same people
after the Reorganizations.

Response:                         The
Registrant will clarify that the portfolio managers for the Funds are expected to be the same before and after the Reorganizations.

Comment
No. 7:               As a global comment for each proposal, please
apply all applicable comments previously provided to the Registrant by the Staff on Post-Effective Amendment No. 105 relating to
the registration of the Acquiring Funds.

Response:                         Please
see the letter on behalf of the Registrant responding to the comments provided in connection with Post-Effective Amendment No. 105,
as filed on May 28, 2021 as accession number 0001104659-21-074248. We will incorporate any comments in a manner consistent with the Acquiring
Funds’ registration statement.

Comment
No. 8:               For each proposal, under “Investment
Restrictions,” please add a brief description of the differences in investment restrictions after the initial sentence.

Response:                         The
Registrant will revise the disclosure accordingly.

Comment
No. 9:               In the “What are the fees and expenses
of the Fund and what can I expect them to be after the Reorganization?” section for each proposal, please clarify that Class A
shares of the Combined Fund will be subject to any applicable sales charges and that the Acquiring Fund is, and Combined Fund will be,
subject to a small account fee whereas the Target Fund is not subject to such a fee. Please add a discussion of these differences to the
Q&A section.

Response:                         The
Registrant will revise the disclosure accordingly.

Comment
No. 10:             Please confirm that, when the performance for Class A shares of the
Acquiring Funds is shown after the reorganizations, the effect of the Class A sales load will be reflected in the historical performance.

Response:                         The
Registrant confirms that performance will reflect the impact of the Class A sales load.

Comment
No. 11:             In footnote 4 of each fee and expense table, please disclose whether the
Adviser’s ability to recoup expenses previously limited from the Target Fund would continue after the Reorganization.

Response:                         The
Registrant has added the following: “The Adviser’s ability to recoup management fees previously limited and/or expenses
previously paid by the Adviser with respect to the Target Fund will not continue after the Reorganization.”

Comment
No. 12:             Please add a proposal to adjourn the Meeting per Rule 14a-4 of
the Securities Exchange Act of 1934.

Response:                         The
Registrant respectfully declines to include an additional proposal. The Registrant does not view adjournment to permit further solicitation
of proxies as a substantive proposal for which proxies must be independently solicited. The history of proposed Rule 20a-4 under
the 1940 Act is instructive in this regard.

Proposed Rule 20a-4 “would have prohibited any adjournment
of a meeting of shareholders of a registered investment company which related to a proposal requiring shareholder approval if a quorum
pursuant to state law were present at such meeting.”(1) However, the SEC withdrew proposed Rule 20a-4, and instead noted
that “[i]nvestment company management must weigh carefully the decision whether to adjourn a shareholder meeting for the purpose
of soliciting shareholders to obtain additional proxies in an effort to secure sufficient votes to pass a particular proposal or proposals.”(2) The
SEC’s statements in its Statement on Adjournment expressly authorize investment company management to decide whether to adjourn
a shareholder meeting for the purpose of soliciting shareholders to obtain additional proxies, subject to management’s fiduciary
duty. Moreover, had the SEC considered the question of adjournment to be a substantive proposal requiring a separate proposal, proposed
Rule 20a-4 and the Statement on Adjournment would not have been necessary.

The Registrant is not aware of any published regulatory authority requiring
stockholder pre-approval for an adjournment, excluding adjournments from the scope of Rule 14a-4(c)(7)(3) or otherwise prohibiting
the actions provided for in the noted disclosure.

Comment
No. 13:             In “Exhibit B - Investment Restrictions,”
please highlight any differences in the Funds’ fundamental investment restriction related to diversification.

Response:                         Each
Fund is a diversified open-end management investment company. The Registrant has added disclosure that clarifies this in the Proxy Statement/Prospectus.

Comment
No. 14:             Please apply comments previously provided on Post-Effective Amendment No. 105
to Exhibit C as applicable.

Response:                         Please
see the letter on behalf of the Registrant responding to the comments provided in connection with Post-Effective Amendment No. 105,
as filed on May 28, 2021 as accession number 0001104659-21-074248. The Registrant will incorporate any comments in a manner consistent with
the Acquiring Funds’ registration statement.

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Should you have any questions concerning the above, please call the
undersigned at (202) 261-3351.

    Very truly yours,

    /s/ Megan Johnson

Megan Johnson