GOODWIN PROCTER          Goodwin Procter LLP            T: 617.570.1000
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April 28, 2006


Van Eck Funds
99 Park Avenue
New York, New York 10016

Ladies and Gentlemen:

As counsel to Van Eck Funds (the "Trust"), a voluntary association with
transferable shares under Chapter 182 of the Massachusetts General Laws,
commonly referred to as a "Massachusetts business trust", we have been asked to
render our opinion in connection with the registration by the Trust of an
unlimited number of shares, par value $.001 per share (the "Shares"), of the
Trust representing interests in the Class I of Emerging Markets Fund, Global
Hard Assets Fund, and International Investors Gold Fund, each a portfolio series
of the Trust, as more fully described in the prospectus and statement of
additional information contained in Post-Effective Amendment No. 66 (the
"Amendment") to the Registration Statement on Form N-1A (Registration No.
002-97596) of the Trust (the "Registration Statement").

We have reviewed  such  documents  and made such  examination  of law as we have
deemed appropriate to give the opinion expressed below. We have relied,  without
independent verification,  on a certificate of the Secretary of the Commonwealth
of  Massachusetts  and, as to matters of fact  material to the opinion set forth
below,  on a  Certificate  of the Secretary of the Trust.  In addition,  we have
assumed that the Shares will be sold for such  consideration  and in  accordance
with such terms and conditions as set forth in the  Registration  Statement,  as
amended  and/or  supplemented  from time to time and that the  ownership  of the
Shares will be duly recorded in the books of the Trust.

The  opinion  expressed  below is  limited  to the laws of the  Commonwealth  of
Massachusetts.

Based upon the foregoing, we are of the opinion that the Shares, when sold, will
be validly issued, fully-paid and non-assessable by the Trust.

We hereby consent to the filing of this opinion as an exhibit to the
Registration Statement. In giving such consent, we do not admit that we are in
the category of persons whose consent is required under Section 7 of the
Securities Act of 1933, as amended, or the rules and regulations thereunder.

Very truly yours,

/s/ Goodwin Procter LLP

GOODWIN PROCTER LLP