[Dechert LLP Letterhead]


April 25, 2007

Via EDGAR Correspondence

Min S. Oh, Esq.
Securities and Exchange Commission
Division of Investment Management
100 F Street Northeast
Washington, D.C. 20549


Re:  Russell   Investment   Funds  (SEC  File  Nos.   33-18030  and   811-05371)
     Post-Effective Amendment to Registration Statement Filed January 31, 2007

Dear Mr. Oh:

Pursuant to your request,  this letter responds to certain comments you provided
to Tiffany  Marosits and me in a  telephonic  discussion  on Tuesday,  March 20,
2007, regarding  Post-Effective  Amendment No. 24 to the Registration  Statement
for Russell Investment Funds (the "Registrant") under the Securities Act of 1933
filed with the Securities and Exchange  Commission (the "Commission") on January
31, 2007.  Summaries of the comments,  and our responses  thereto,  are provided
below. I have either  responded to your questions and comments or have described
how I will  address  your  comments  in the  prospectus  and  SAI  contained  in
Post-Effective  Amendment  No.  29 to the  Registration  Statement  to be  filed
pursuant to Rule 485(b) under the Securities Act of 1933.

Below are responses to certain comments that you requested be filed prior to the
effective  date.  Responses to your  remaining  comments will be filed  shortly.
Please note that I have retained the original numbering of the comments for ease
of reference.

Response to Comments

The  responses to your  comments  below are  numbered  according to the order in
which you had given the  comments.  Capitalized  terms have the same  meaning as
defined in the prospectus unless otherwise indicated.

1. Comment:  Please explain how the LifePoints  Variable Target Portfolio Series
complies with  applicable  sections and rules of the  Investment  Company Act of
1940  (i.e.,  what  sections  are you relying  upon in the absence of  exemptive
relief).

   Response:  The LifePoints  Variable Target Portfolio series relies on Section
12(d)(1)(G) of the Investment Company Act of 1940.

7(b).  Comment:  In the Fees and  Expenses  section  of the  Prospectus,  please
confirm that the calculation of the Acquired (Underlying) Fund Fees and Expenses
column is in compliance with  Instruction 3 of Item 3 of Form N-1A.  Please also
delete the second fee table.

   Response:  We can confirm that the  calculation of the Acquired  (Underlying)
Fund Fees and Expenses column is in compliance  with  Instruction 3 of Item 3 of
Form N-1A. We respectfully  decline to remove the second table from the Fees and
Expenses section of the Prospectus as we believe it provides  shareholders  with
relevant information about the Underlying Funds.

7(c).  Comment:  In the Fees and  Expenses  section  of the  Prospectus,  please
confirm the exemptive order cited in footnote ** is applicable to the Funds, and
please provide the citation for the order as well as the notice.

   Response:  We can confirm  that Frank  Russell  Investment  Company,  et al.,
Investment Company Act Release Nos. 25416 (Notice) (February 12, 2002) and 25458
(Order) (March 12, 2002) is applicable to the Funds.

15. Comment:  In the Mixed and Shared Funding section of the Prospectus,  please
explain the basis for mixed and shared funding  relief,  including  citations to
the notice and order, and whether it is applicable to the Funds.

   Response:  The mixed and shared  funding relief results from In the Matter of
Russell  Investment  Funds,  et al.,  Investment  Company Act Release Nos. 26351
(Notice)  (February  11,  2004) and 26381  (Order)  (March  9,  2004),  which is
applicable to the Funds.


Please call me at (617)  728-7155 or John V.  O'Hanlon at (617)  728-7111 if you
have any questions.


Very truly yours,


/s/ Joshua A. Weinberg

Joshua A. Weinberg



cc:     Mary Beth Rhoden

       John V. O'Hanlon