Re:
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Selected American Shares, Inc. (40 Act File No.: 811-00051)
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Selected International Fund, Inc. (40 Act File No.: 811-01533)
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1.
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We noted disclosure of significant ownership in the funds per review of the financial
statements. If you could, please explain how large shareholder or shareholder concentration risk is addressed in the summary and statutory prospectus. Please consider how such redemptions could result in tax consequences and negatively
impact the funds’ NAV, liquidity, brokerage cost, and the ability to execute the funds’ investment strategy.
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Affected Fund
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# Principal Risks
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Selected International Fund
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13
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Davis International Fund
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13
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Davis Appreciation & Income Fund
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18
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Davis Research Fund
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11
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Davis Select U.S. Equity ETF
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16
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Davis Select International ETF
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18
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Davis Select Financial ETF
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19
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Davis Select Worldwide ETF
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18
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1.
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The Registrants are responsible for the accuracy and adequacy of the disclosures in the Registrants’ filings;
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2.
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Staff comments or changes to disclosure in response to staff comments in the filings reviewed by the staff do not foreclose
the Commission from taking any action with respect to the filings; and
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3.
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The Registrants 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.
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