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October 13, 2022

VIA EDGAR

Securities and Exchange Commission

100 F Street, NE

Washington, D.C. 20549

Re:	The Lazard Funds, Inc.
	Securities Act File No. 333-40682; Investment Company Act File No. 811-06312
	Post-Effective Amendment No. 146

Ladies and Gentlemen:

On behalf of The Lazard Funds, Inc. (the “Fund”), attached herewith for filing, pursuant to Rule 485(a) under the Securities Act of 1933, as amended, is the above-referenced Post-Effective Amendment No. 146 to the Fund’s Registration Statement on Form N-1A (the “Amendment”). This filing relates to Lazard US Convertibles Portfolio, a new series of the Fund, and should have no effect on the existing series of the Fund. No fees are required in connection with this filing.

Should you have any questions regarding the Amendment, please do not hesitate to contact me at (212) 649-8707 or Claire Hinshaw at (617) 728-7189.

Very truly yours,

/s/ Robert Spiro

Robert Spiro