Unassociated Document

On behalf of the Matthews International Funds, doing business as the Matthews Asia Funds (the “Registrant”), we hereby respond to the oral comments provided on October 25, 2010 by Ms. Patricia Williams of the Commission’s staff with respect to the Registrant’s Post-Effective Amendment No. 41 filed on August 27, 2010. Changes to the Registrant’s disclosure in response to those comments are reflected in its Post-Effective Amendment No. 42 filed on or about October 29, 2010.

1.	Comment: Please delete the strategy headers (e.g., “Asia Growth and Income Strategies”, “Asia Growth Strategies”, etc.) on the top of the first page of each Fund summary.

Response: The text is part of the fund graphic and design used on pages in each summary in the non-EDGAR version of the prospectus and is not part of the text sections for the required items in the summary. For that reason, the Registrant declines to make this change.

2.	Comment: For the Asian Growth and Income Fund and the Pacific Tiger Fund, please explain why “where it is organized” and “other factors” subject the Funds to the economic risks and fortunes of the Asian region under Principal Investment Strategies.

Response: The organizational jurisdiction and other factors are utilized to determine whether a company is considered within Asia or the Pacific region, and therefore are reasonable factors in determining whether the fund will invest in such companies. For example, legal and regulatory considerations in organizing a company also can affect a company on an on-going basis, and those factors are often tied to the economic condition of a country because of governmental and regulatory activities in response to economic conditions.

3.	Comment: For all Funds, please provide greater specificity regarding the “Risks Associated with Emerging Markets” under Principal Risks in each Fund summary.

Response: Comment accepted and deferred. As identical risk disclosure language is utilized in the Registrant’s other prospectus, it is not practical to effect revisions to that section for each Fund summary at this time. The Registrant hereby undertakes to make appropriate revisions upon the next amendment of its registration statement in a manner to conform disclosure in both prospectuses.

4.	Comment: For all Funds, please explain why “Convertible Securities” is listed as a Principal Risk but is not listed as a Principal Investment Strategy in each Fund summary.

Response: Convertible Securities are listed under the Principal Investment Strategy and Principal Risks for Asian Growth and Income Fund, Asia Dividend Fund, China Dividend Fund, Asia Pacific Fund and India Fund. None of the other funds mention convertible securities in the fund summary as either a strategy or risk.

5.	Comment: For each Fund except China Dividend Fund, please note that past performance both before and after taxes is not a prediction of future results.

6.	Comment: For the Asian Growth and Income Fund, please provide additional disclosure regarding the MSCI All Country Far East ex Japan Index as required by Instruction 2(b) to Item 4 of Form N-1A.

Response: Comment accepted. Footnote has been revised to comply with Instruction 2(b) – Table to Item 4 of Form N-1A.

8.	Comment: Please state whether the Investment Objectives of the Funds listed on page 55 of the prospectus are fundamental to each Fund.

9.	Comment: Please identify the location of the portfolio holdings disclosure as required by Item 9(d) of Form N-1A.

Response: Please see the disclosure under the heading “Disclosure of Portfolio Holdings” in “Investing in Matthews Asia Funds” on page 72 of the prospectus.

10.	Comment: Please note in the first table under “Management of the Funds” in the Statement of Additional Information that the information provided under “Other Trusteeships/ Directorships (number of portfolios) Held by Trustee” is for the last five (5) years.

11.	Comment: Please provide more specific disclosure under “Information about Each Trustee’s Qualifications, Experience, Attributes or Skills”.

Response: Comment accepted and deferred. Given the very short amount of time available until the filing and printing deadlines for this Post-Effective Amendment, it was not practical to effect significant revisions to that section. The Registrant hereby undertakes to make appropriate revisions upon the next amendment of the registration statement.

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Staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing; and

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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.