Bingham McCutchen LLP

One Federal Street

Boston, MA 02110

March 6, 2013

Securities and Exchange Commission

Division of Investment Management

100 F Street, N.E.

Washington, DC 20549

Re: Pioneer Value Fund

Registration Statement on Form N-14

(File No.                )

Ladies and Gentlemen:

On behalf of our client, Pioneer Value Fund (the “Registrant”), a Delaware statutory trust, we are hereby filing a combined information statement and registration statement on Form N-14, with exhibits (the “Registration Statement”).

The Registration Statement relates to a proposed reorganization of Pioneer Research Fund with the Registrant.

The Registration Statement is being filed pursuant to Rule 488 under the Securities Act of 1933, as amended.  It is proposed that this filing will become effective on April 5, 2013 pursuant to Rule 488.

Please call the undersigned at (617) 951-8458 or Toby R. Serkin at (617) 951-8760 with any questions relating to the filing.

Sincerely,

/s/ Jeremy B. Kantrowitz

Jeremy B. Kantrowitz