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800 Nicollet Mall                                               RICHARD J. ERTEL
BC-MN-HO4N                                                               COUNSEL
Minneapolis, MN 55402                                Direct line: (612) 303-7987
                                                            Fax:  (612) 303-4223

August 12, 2008

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 July 25, 2008

Dear Ms. Browning:

The purpose of this letter is to respond to the comments that you transmitted by
telephone on August 6, 2008 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.   REVIEW YOUR DISCUSSION OF THE MANAGER-OF-MANAGERS AUTHORITY THROUGHOUT THE
     DIFFERENT SECTIONS OF THE FILING (E.G., QUESTION & ANSWER SECTION, PROXY
     STATEMENT, ETC.) TO ENSURE THAT YOUR DISCLOSURES ARE CONSISTENT AND
     COMPLETE IN DESCRIBING THE AUTHORITY GRANTED TO, AND LIMITATIONS ON, THE
     ADVISOR UNDER SUCH AUTHORITY. FOR EXAMPLE, NOTE THAT MANAGER-OF-MANAGERS
     WILL ALLOW THE ADVISOR TO CHANGE SUB-ADVISORS WITHOUT HAVING TO OBTAIN
     SHAREHOLDER APPROVAL OF SUCH A CHANGE. ALSO, MAKE IT CLEAR THAT THIS
     AUTHORITY EXTENDS ONLY TO THE HIRING OF UNAFFILIATED SUB-ADVISORS.

     We made the following changes in response to this comment:

     -    In the letter to shareholders from the president of the Fund, we have
          clarified that manager-of-managers authority would allow FAF Advisors,
          Inc. (the "Advisor") to make changes to sub-advisors and change the
          terms of the sub-advisory agreements "without having to seek
          shareholder approval."

     -    In that same letter, we have also added the following sentence
          regarding the hiring of affiliated sub-advisors under the
          manager-of-managers authority:

               "The Advisor may not enter into a sub-advisory agreement with any
               affiliated sub-advisor without that agreement being approved by
               the Fund's shareholders."



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     -    In the "Important Information" question and answer section, under
          "What is a manager-of-managers structure?" we changed "and the terms
          of sub-advisory agreements without holding a shareholder meeting" to
          read as follows:

               ". . . or materially amend existing sub-advisory agreements
               without having to seek shareholder approval."

2.   MAKE IT CLEAR WHO (E.G., J.P. MORGAN) WILL BE RESPONSIBLE FOR THE
     DAY-TO-DAY MANAGEMENT OF THE FUND BETWEEN THE TIME THE PROXY IS FILED WITH
     THE COMMISSION AND THE ANTICIPATED SWITCH FROM J.P. MORGAN TO ALTRINSIC AND
     HGI.

     In the proxy statement, in the last paragraph under "Background" of both
     Proposal 1 and Proposal 2, we have added the following sentence in relation
     to the expected effective date (i.e., November 1, 2008) of the change in
     sub-advisors:

               "Until that time, JPMorgan is expected to continue in its role as
               sub-advisor to the Fund."

3.   CONFIRM THAT ALL MATERIAL DIFFERENCES BETWEEN THE J.P. MORGAN AGREEMENT AND
     THE PROPOSED AGREEMENTS WITH ALTRINSIC AND HGI HAVE BEEN DISCLOSED. IN THE
     Q&A DISCUSSION OF THE SUB-ADVISORY FEE INCREASE ASSOCIATED WITH THE CHANGE
     TO THE NEW SUB-ADVISORS, IT STATES THAT THE "INCREASE IN FEES WILL BE BORNE
     ENTIRELY BY THE ADVISOR." IS THIS A CONTRACTUAL OBLIGATION ARISING FROM THE
     ADVISORY AGREEMENT BETWEEN THE FUND AND THE ADVISOR? IF SO, PLEASE MAKE
     REFERENCE TO THAT AGREEMENT.

     We can confirm that all material differences between the J.P. Morgan
     Agreement and the proposed Altrinsic and HGI agreements have been disclosed
     in the proxy statement.

     We have added the following underlined language to the Q&A discussion of
     the increase in fees to clarify that the Advisor is contractually obligated
     to pay all sub-advisory fees:

               "This increase in fees will be borne entirely by the Advisor and
               paid by the Advisor out of the investment advisory fees it
               receives from the Fund, pursuant to the terms of the Investment
               Advisory Agreement between FAIF and the Advisor."

4.   CONSIDER INCLUDING A DISCUSSION OF THE CHANGE IN INVESTMENT STRATEGY OF THE
     FUND IN THE PROXY STATEMENT, IN ADDITION TO THE DISCUSSION FOUND IN THE
     QUESTION & ANSWER SECTION OF THE FILING. WE SUGGEST THAT YOU RESTATE THE
     FUND'S INVESTMENT OBJECTIVE AND NOTE THAT IT WILL NOT CHANGE UPON THE
     CHANGE IN SUB-ADVISORS AND STRATEGIES. ALSO CONSIDER MOVING THE DISCLOSURE
     OF THE NEW PORTFOLIO MANAGERS INTO THIS SAME DISCUSSION WITHIN THE PROXY
     STATEMENT AND CONSIDER GIVING IT MORE PROMINENCE WITHIN THE PROXY
     STATEMENT.

     We have inserted the following paragraph as the third paragraph of the
     definitive proxy statement:

               "Should shareholders approve the sub-advisory agreements with
               Altrinsic and HGI, the Fund's investment strategy will change
               from that employed by the



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               Fund's current sub-advisor, J.P. Morgan Investment Management
               Inc. ('JPMorgan'). Altrinsic and HGI will each be responsible for
               separately managing a portion of the Fund's assets, as assigned
               by the Advisor. The Advisor will be responsible for allocating
               the Fund's assets between Altrinsic and HGI and the Advisor will
               manage the portion of the Fund's assets not allocated to a
               sub-advisor. Teams of portfolio managers at both Altrinsic and
               HGI will use their own investment strategies when managing their
               respective portion of the Fund's assets, which will differ from
               the investment strategy currently used by JPMorgan. Altrinsic
               will take a 'value' style approach to investing its portion of
               Fund assets, similar to JPMorgan; however, Altrinsic looks for
               value opportunities across a broader range of market
               capitalizations. HGI will employ a 'growth' style to investing
               its portion of the Fund's assets. The investment strategies
               utilized by Altrinsic and HGI, along with information on their
               respective portfolio management teams, are further described
               below under 'Additional Information about Altrinsic' and
               'Additional Information about HGI,' respectively. The Fund's
               investment objective of 'long-term growth of capital' will remain
               the same."

     We believe adding this discussion near the beginning of the proxy
     statement, with references back to additional information on the specific
     strategies employed by the proposed sub-advisors, as well as their
     portfolio management teams, appropriately emphasizes the shift in strategy
     without detracting from the discussion of the proposals that shareholders
     are being asked to consider.

5.   ONE OF THE FACTORS THE BOARD CONSIDERED IN CHANGING SUB-ADVISORS WAS THE
     "ECONOMIES OF SCALE" THAT WOULD BE REALIZED THROUGH THE HIRING OF BOTH
     ALTRINSIC AND HGI. PLEASE EXPLAIN THIS FURTHER IN THE PROXY STATEMENT.

     The factor has been revised as follows for both Altrinsic and HGI:

               "economies of scale that might result from the growth in the
               Fund's assets and from [Altrinsic's][HGI's] management of both
               the Fund and International Select Fund and any other benefit that
               [Altrinsic][HGI] may derive from its relationship with the Fund."

6.   YOU REFERENCE THAT FAIF AND THE ADVISOR HAVE RECEIVED A MANAGER-OF-MANAGERS
     EXEMPTIVE ORDER FROM THE SEC. PLEASE INCLUDE THE DATE OF THE ORDER IN THE
     PROXY STATEMENT.

     In the discussion of Proposal 3 in the proxy statement, specifically in the
     second paragraph under "Background," we added a reference to the date of
     the exemptive order, which was May 30, 2007.

7.   IN FOOTNOTE 1 TO THE TABLE REGARDING FUNDS FOR WHICH HGI ACTS AS INVESTMENT
     ADVISOR OR SUB-ADVISOR THAT HAVE SIMILAR INVESTMENT OBJECTIVES TO THAT OF
     THE FUND, PLEASE CONFIRM WHETHER HGI HAS THE ABILITY TO RECOUP ANY OF THE
     WAIVED FEES. IF THEY ARE ALLOWED TO RECOUP ALL OR A PORTION OF THE WAIVED
     AMOUNTS, THE DISCLOSURE SHOULD STATE AS SUCH AND HGI CANNOT CLAIM THAT IT
     HAS CONTRACTUALLY AGREED TO WAIVE FEES.



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     HGI does have the ability to recoup the fees within one year of the waiver,
     under certain conditions. That being the case, the footnote has been
     revised as follows to describe both the voluntary nature of the waiver and
     the ability of HGI to recoup the fees:

               "HGI has provided a letter agreement to Hansberger International
               Series ("HIS") under which HGI will voluntarily waive a portion
               of its management fee (and, to the extent necessary, bear other
               expenses) if total expenses, not including brokerage, interest,
               taxes, deferred organizational and extraordinary expenses, exceed
               1.00% and 1.15% (1.25% and 1.40% for the Emerging Markets Fund)
               for the Institutional and Advisor Class shares of each HIS Fund,
               respectively. HGI may recoup the waived fees within one year
               following the waiver."

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.

     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