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800 Nicollet Mall                                               RICHARD J. ERTEL
BC-MN-HO5F                                                               COUNSEL
Minneapolis, MN 55402                                Direct line: (612) 303-7987
                                                             Fax: (612) 303-4223

August 16, 2007

Ms. Kimberly Browning                                VIA EDGAR
Office of Disclosure and Review
Division of Investment Management
Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, DC 20549

Re:  First American Investment Funds, Inc.
     SEC File Nos. 033-16905 and 811-05309
     Response to Staff Comments on Preliminary Proxy Statement (Form PRE 14A)
     Filed with the Commission on August 2, 2007

Dear Ms. Browning:

The purpose of this letter is to respond to the comments that you transmitted by
telephone on August 16, 2007 regarding the preliminary proxy statement for the
above-listed registrant (the "Registrant"), related to International Fund (the
"Fund"), a series of the Registrant. Following is our response to your comments,
which appear in bold-face type below.

1.   IN YOUR RESPONSE LETTER DATED AUGUST 14, 2007, YOU STATED THAT THE ADVISOR
     DOES "NOT CONTEMPLATE USING A PERFORMANCE FEE STRUCTURE TO COMPENSATE
     SUB-ADVISORS TO THE FUND." PLEASE DISCLOSE IN THE PROXY STATEMENT THE
     POSSIBILITY, HOWEVER REMOTE, THAT A PERFORMANCE FEE STRUCTURE MAY BE
     IMPLEMENTED IN THE FUTURE AND THAT, IF SHAREHOLDERS APPROVE THE
     MANAGER-OF-MANAGERS STRUCTURE, SHAREHOLDERS WOULD NOT HAVE THE OPPORTUNITY
     TO APPROVE SUCH STRUCTURE.

     We have added the following sentence to the second paragraph under
     "Description of the Manager-of-Managers Structure" on page 3 of the proxy
     statement, immediately following the first sentence in that paragraph:

          For example, should the Advisor choose to compensate unaffiliated
          sub-advisors based on a rate that adjusts upward or downward based
          upon the Fund's performance relative to its benchmark index (a
          "performance-based fee"), rather than the current fixed rate fee
          structure, shareholders would not be asked to approve such a change.

In connection with the review of the above-referenced filing by the staff of the
Securities and Exchange Commission (the "Commission"), the Registrant hereby
acknowledges that:

     1.   The Registrant is responsible for the adequacy and accuracy of the
          disclosure in the filing.



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     2.   Staff comments or changes to disclosure in response to staff comments
          in the filing reviewed by the staff do not foreclose the Commission
          from taking any action with respect to the filing.

     3.   The Registrant may not assert staff comments as a defense in any
          proceeding initiated by the Commission or any person under the federal
          securities laws of the United States.

If you need anything further, please contact me at your earliest convenience at
612-303-7987. Thank you for your help.

                                        Sincerely,


                                        /s/ Richard J. Ertel

                                        Richard J. Ertel
                                        Assistant Secretary to the Registrant