SEWARD & KISSEL LLP
One Battery Park Plaza
New York, New York 10004
Telephone: (212) 574-1598
Facsimile: (212) 480-8421
March 26, 2013
Securities and Exchange Commission
Division of Investment Management
100 F Street, N.E.
Washington, DC 20549
| Re: | Fairholme Funds, Inc. (the “Company”) |
| File Nos.: 333-88517 and 811-09607 |
Ladies and Gentlemen:
Attached herewith please find Post-Effective Amendment No. 28 under the Securities Act of 1933 (the “1933 Act”), and Amendment No. 30 under the Investment Company Act of 1940, as amended, to the Company’s Registration Statement on Form N-1A (the “Amendment”). The Amendment is filed pursuant to paragraph (b) of Rule 485 under the 1933 Act and is marked in accordance with Rule 310 of Regulation S-T.
Please direct any comments or questions to Paul M. Miller at 202.737.8833, or the undersigned at 212.574.1598.
| Sincerely, | ||||
| /s/Keri E. Riemer | ||||
| Keri E. Riemer | ||||