[Chadbourne & Parke Letterhead]


                                   March 25, 2015


Securities and Exchange Commission
Division of Corporation Finance
100 F Street, NE
Washington, DC 20549



       Re:The Adams Express Company ("Company")
          Definitive Proxy Statement on Form DEF 14A
          Filed on March 10, 2015
          (File No. 811-00248)


Ladies and Gentlemen:

          This letter is in response to comments of the staff
(the "Staff") of the Securities and Exchange Commission made
during telephone conversations between Amy Miller, Senior Counsel
- the Division of Investment Management, and Kevin Smith, of this
office, in connection with the above-referenced definitive proxy
statement.  Specifically, Ms. Miller asked us to confirm that the
Company's pending name change from "The Adams Express Company" to
"Adams Diversified Equity Fund, Inc." is consistent with the
Company's investment policies and Rule 35d-1 under the Investment
Company Act of 1940, as amended.  We confirm that the Company
has, as part of its investment objectives and policies, a policy
that "Normally, the bulk of the Company's assets will be invested
in common stocks or securities convertible into common stocks".
As discussed, the Company is revising its compliance policies to
clarify that the Company interprets the foregoing policy to mean
that at least 80% of the Fund's assets are invested in equities
such as common stocks and securities convertible into common
stocks.  The Company will include disclosure in its next annual
report to shareholders in connection with the name change
informing shareholders of this clarification to its compliance
policies.

          Please telephone Kevin Smith at (212) 408-1092 if you
require additional information.

                              Very truly yours,






                              /s/ CHADBOURNE & PARKE LLP