February 24, 2006

Securities and Exchange Commission100 F Street, N.E. Washington, D.C. 20549

Re: T. Rowe Price International Funds, Inc. File Nos.: 002-65539/811-2958 Post-Effective Amendment No.: 91

Commissioners:

We are counsel to the above-referenced registrant which proposes to file, pursuant to paragraph (b) of Rule 485 (the "Rule"), the above-referenced Post-Effective Amendment (the"Amendment") to its registration statement under the Securities Act of 1933, as amended.

Pursuant to paragraph (b) of the Rule, we represent that the Amendment does not contain disclosures which would render it ineligible to become effective pursuant to paragraph (b) of theRule.

Sincerely,

/s/Willkie Farr & Gallagher LLPWillkie Farr & Gallagher LLP