Deutsche Investment Management Americas Inc.
                                 One Beacon Street
                                 Boston, MA 02108

                                 October 2, 2009


Securities and Exchange Commission
100 F Street, N.E.
Washington, DC 20549

RE:      Post-Effective Amendment No. 116 to the Registration Statement on Form
         N-1A of DWS International Value Opportunities Fund (the "Fund"), a
         series of DWS International Fund, Inc. (the "Corporation") (Reg. Nos.
         02-14400, 811-00642)

Ladies and Gentlemen:

         On behalf of the Fund, we are filing today through the EDGAR system
Post-Effective Amendment No. 116 to the Fund's Registration Statement on Form
N-1A (the "Amendment").

         The Amendment is being filed under paragraph (a)(1) of Rule 485 under
the Securities Act of 1933 and Rule 8b-16 under the Investment Company Act of
1940 for review and comment by the staff of the Securities and Exchange
Commission (the "Commission"). Pursuant to Rule 485(a)(1), the Fund has
designated on the facing sheet to the Registration Statement that the Amendment
become effective on December 1, 2009. No fees are required in connection with
this filing.

         The principal purpose of the Amendment is to comply with the recent
amendments to Form N-1A that require the statutory prospectus of every mutual
fund to include a summary section at the front of the prospectus. The Amendment
has been electronically coded to show changes from the Fund's Class A, C
Prospectus and Statement of Additional Information, filed with the Commission on
December 1, 2008 in Post-Effective Amendment No. 113.


         Please direct any comments or questions relating to the Amendment to
the undersigned at 617-295-3011.

                              Sincerely yours,

                              /s/James M. Wall

                              James M. Wall, Esq.
                              Director and Counsel
                              Deutsche Investment Management Americas Inc.



cc:      Adam Schlichtmann, Esq., Ropes & Gray