Kimberly Karcewski Vargo
202.346.4304
KVargo@
goodwinprocter.com Goodwin Procter llp
Counselors at Law
901 New York Avenue NW
Washington, DC 20001
T: 202.346.4000
F: 202.346.4444

July 9, 2014

VIA EDGAR

U.S. Securities and Exchange Commission

Division of Investment Management

100 F Street, NE

Washington, DC 20549

Re: Van Eck Funds (the “Registrant”)
Post-Effective Amendment No. 124 to Registration Statement on Form N-1A
File Nos. 002-97596; 811-04297

Ladies and Gentlemen:

In connection with the registration of the Registrant under the Investment Company Act of 1940, as amended (the “1940 Act”), and the issuance of an indefinite number of its securities under the Securities Act of 1933, as amended (the “1933 Act”), we are transmitting for filing on EDGAR pursuant to Rule 485(a) under the 1933 Act Post-Effective Amendment No. 124 and Amendment No. 125 under the 1940 Act to the Registrant’s Registration Statement on Form N-1A.

The purpose of the filing is to effect certain material changes to the prospectus and statement of additional information for the Long/Short Equity Fund, a series of the Registrant (the “Fund”). The Fund plans to change its name from the Long/Short Equity Fund to the Long/Short Equity Index Fund effective upon the implementation of the changes.

Should you have any questions, please contact me at (202) 346-4304.

Very truly yours,

/s/ Kimberly Karcewski Vargo

Kimberly Karcewski Vargo