STROOCK & STROOCK & LAVAN LLP
                                 180 MAIDEN LANE
                             NEW YORK, NY 10038-4982


                                                                     JANNA MANES
                                                                    212.806.6141



October 15, 2004




Securities and Exchange Commission
Judiciary Plaza
450 Fifth Street, NW
Washington, D.C.  20549


Attention:  Keith A. O'Connell, Esq.


Re:      The Lazard Funds, Inc.
         (REGISTRATION NOS: 811-06312; 33-40682)
          -------------------------------------

Ladies and Gentlemen:

On behalf of the above-referenced fund (the "Fund"), transmitted for filing
pursuant to Rule 485(a)(2) under the Securities Act of 1933, as amended (the
"1933 Act"), is Post-Effective Amendment No. 30 to the Fund's Registration
Statement (the "Amendment"). The Amendment is being filed in order to add a new
series to the Fund, the Lazard U.S. Strategic Equity Portfolio (the Portfolio").

LAZARD U.S. STRATEGIC EQUITY PORTFOLIO. The Portfolio's investment objective is
to seek long-term capital appreciation. The Portfolio will invest primarily in
equity securities, principally common stocks, of U.S. companies that Lazard
Asset Management LLC ("LAM"), the Portfolio's investment adviser, believes are
undervalued based on their earnings, cash flow or asset values. The Portfolio
will generally invest in large-size companies, but may invest in companies with
varying market capitalizations and will maintain opportunistic exposure to
midcap companies, as determined by LAM. The Portfolio may invest in companies
with market capitalizations as small as $500 million. Under normal
circumstances, the Portfolio will invest at least 80% of its assets in equity
securities. The Portfolio will typically hold securities of between 50 and 70
different issuers on a long-term basis. The Portfolio may invest up to 15% of
its total assets in non-U.S. equity securities. Except as noted above, each of
the investment policies and strategies of the Portfolio are those that may be
employed by the other Fund portfolios that invest






Securities and Exchange Commission
October 15, 2004
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primarily in equity securities. Disclosure regarding such investments and
strategies is the same as the existing disclosure for such other portfolios,
which has previously been reviewed by the staff (the "Staff") of the Securities
and Exchange Commission.

The distribution of Portfolio Institutional Shares and Open Shares and the
process for determination of net asset value will be identical to that of the
other Fund portfolios.

The investment policies and operations of the Portfolio do not appear to raise
novel issues or problem areas that warrant particular attention of the Staff in
reviewing the Amendment. Consequently, on behalf of the Fund, we request that
the Amendment be given selective review by the Staff.

The Fund intends to file a further post-effective amendment pursuant to Rule
485(b) prior to the effective date of the Amendment in order to update financial
and other information for the other Fund portfolios to fill in certain
information that is incomplete in the Amendment and to respond to any comments
the Staff may have on the Portfolio.

Please telephone the undersigned or Stuart H. Coleman of this office at
212.806.6049 if you have any questions.

Very truly yours,

/s/ Janna Manes

Janna Manes

cc:   Stuart H. Coleman, Esq.