February 13, 1998
Securities and Exchange Commission
Division of Disclosure and Review
Office of Disclosure and Review
450 Fifth Street, N.W.
Washington, D.C. 20549
Re: Davis New York Venture Fund, Inc.
Post-Effective Amendment No. 56 under the
Securities Act of 1933, File No. 2-29858, and
Amendment No. 31 under the Investment Company
Act of 1940, File No. 811-1701.
Dear Sir or Madam:
On behalf of Davis New York Venture Fund, Inc. (the "Company"), attached for
filing pursuant to Rule 485(a)(2) under the Securities Act of 1933 is Post-
Effective Amendment No. 56 to the Company's Registration Statement on Form
N-1A which is being filed for the purpose of adding a new portfolio, Davis
Growth & Income Fund. It is proposed that this new portfolio be declared
effective May 1, 1998.
The Davis Growth & Income Fund is a growth and income fund patterned after the
existing Davis New York Venture Fund.
Questions regarding this filing should be directed to me at (505) 820-3055 or,
in my absence, to Jessica Droeger, Esq. D'ancona & Pflaum, at (312) 580-2014.
Very truly yours,
/s/ Thomas D. Tays
Thomas D. Tays
