[LETTERHEAD OF PAUL, HASTINGS, JANOFSKY & WALKER LLP]


(212) 318-6962
matthewvanwormer@paulhastings.com


May 17, 2005                                                         43490.00001


VIA EDGAR

Ms. Laura Hatch
Securities and Exchange Commission
Division of Investment Management
450 Fifth Street, N.W.
Washington, DC  20549

Re:     The Westwood Funds (811-04719)
        -----------------------------

        Dear Ms. Hatch:

        This letter responds to your comments communicated to me telephonically
on April 29, 2005, with respect to the preliminary Proxy Statement and form of
proxy for the Westwood Realty Fund (the "Fund"), a series of the Westwood Funds
(the "Trust"), that was filed with the Securities and Exchange Commission via
EDGAR on April 19, 2005 (accession number 0000935069-05-000879). Please note the
following:



               Comment 1: You have requested that we add a sentence explaining
               how the Fund's new name, the "Westwood Alternative Real Income
               Fund," reflects the new investment policy of the Fund.

               Response: The new name of the Fund will be the "Westwood Income
               Fund." We have added a new sentence after the first sentence of
               the first full paragraph on page A-3 which explains how the
               Fund's new name reflects the new income oriented investment
               policy of the Fund.





Ms. Laura Hatch
May 17, 2005
Page 2


               Comment 2: You have requested that we disclose whether the Fund
               will be "non-diversified," and if so, to disclose the risks
               associated with non-diversification.

               Response: We have confirmed that the Fund is, and will remain
               "diversified," and as a result, no additional disclosure is
               required.



               Comment 3: You have informed us that it would be necessary to add
               a second proposal if the Fund originally had a fundamental policy
               of being "concentrated" in the securities of publicly traded
               REITs, and would no longer be "concentrated" in such securities
               as a result of the change in the Fund's investment objective.

               Response: The Fund did not have a fundamental policy of being
               "concentrated" in the securities of publicly traded REITs, and as
               a result, an additional proposal is not necessary.



               Comment 4: You have requested that we include a "Tandy"
               representation letter signed on behalf of the Fund as a
               correspondence filing to be filed with the definitive proxy
               statement.

               Response: We have included such "Tandy" representation in this
               correspondence filing.

        Please note that as instructed, this letter is being transmitted as a
correspondence filing with the copy of the Definitive Proxy.

        Should you have any additional questions or comments, please do not
hesitate to call me at 212-318-6962.






Ms. Laura Hatch
May 17, 2005
Page 3


Very truly yours,


/s/ Matthew Van Wormer
Matthew Van Wormer
for PAUL, HASTINGS, JANOFSKY & WALKER LLP

cc:     The Westwood Funds