COHEN & STEERS INTERNATIONAL REALTY FUND, INC.

280 Park Avenue, 10^th floor

New York, NY 10017

VIA EDGAR

September 30, 2015

Securities and Exchange Commission

450 Fifth Street, N.W.

Washington, D.C. 20549

Attention: Mark Cowan

Re: Cohen & Steers International Realty Fund, Inc. (File No. 811-21677; 333-120705)

Dear Mr. Cowan:

Pursuant to Rule 461 of the General Rules and Regulations under the Securities Act of 1933, as amended, Cohen & Steers International Realty Fund, Inc. hereby requests that the effective date of the above-captioned Registration Statement be accelerated so that it will be declared effective as soon as possible on September 30, 2015 or as soon as possible thereafter.

The request of the representative of the distributor, Cohen & Steers Securities, LLC, will be delivered to you by separate letter.

Very truly yours,
COHEN & STEERS INTERNATIONAL REALTY FUND, INC.
By:	/s/ Tina M. Payne
	Assistant Secretary

COHEN & STEERS SECURITIES, LLC

280 Park Avenue

New York, NY 10017

VIA EDGAR

September 30, 2015

Securities and Exchange Commission

450 Fifth Street, N.W.

Washington, D.C. 20549

Attention: Mark Cowan

Re: Cohen & Steers International Realty Fund, Inc. (File No. 811-21677; 333-120705)

Dear Mr. Cowan:

Pursuant to Rule 461 of the General Rules and Regulations under the Securities Act of 1933, as amended, the undersigned hereby joins in the request of Cohen & Steers International Realty Fund, Inc. that the effective date of the above-captioned Registration Statement be accelerated so that it will be declared effective as soon as possible on September 30, 2015 or as soon as possible thereafter.

Very truly yours,
COHEN & STEERS SECURITIES, LLC
By:	/s/ Tina M. Payne
	Secretary