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The
Growth Fund of America, Inc.
One Market, Steuart
Tower
Suite
1800
San Francisco,
California 94105
Phone (415)
421-9360
Patrick
Quan
Secretary
October 16,
2009
Ms. Laura Hatch,
Staff Accountant
U.S. Securities and
Exchange Commission
100 F Street,
NE
Washington, DC
20549
Re: The
Growth Fund of America, Inc.
File
Nos. 811-00862 and 002-14728
Dear Ms.
Hatch:
This letter is in
response to oral comments we received from you on September 30, 2009 to the
fund’s Post-Effective Amendment No. 85 to the Registration Statement under the
Securities Act of 1933 and Amendment No. 44 to the Registration Statement under
the Investment Company Act of 1940. We appreciate your prompt
response to the filing.
Our responses to
your comments are set forth below. We will incorporate any changes to the fund’s
Registration Statement in a filing pursuant to Rule 485(b) to be automatically
effective on November 1, 2009.
1. Principal
investment strategies – page 3 of the fund’s prospectus
Comment: Please
explain the criteria that portfolio counselors use to determine what common
stocks appear to offer superior opportunities for growth of
capital.
Response: We
have clarified the language in the first paragraph of this section to state that
the fund “seeks to invest in companies that appear to offer superior
opportunities for growth.” Additionally, the second paragraph states
that the fund relies on the judgment of the investment adviser, that the basic
investment philosophy of the investment adviser is to seek to invest in
attractively valued companies that, in its opinion, represent good, long term
investment opportunities and that the investment adviser believes that an
important way to accomplish this is through fundamental
analysis. These are the common ideals that the fund’s portfolio
counselors maintain in managing the fund’s assets. The investment
adviser uses a system of multiple portfolio counselors to manage the fund’s
assets. There are ten portfolio counselors named in the prospectus
who manage their own portion of the fund’s assets, with others that manage
smaller portions of the fund. Each of these portfolio counselors may
use different criteria to determine what, in his/her professional investment
opinion, constitutes a company that appears to offer superior opportunities for
growth of capital. There is not one or two criteria that these
portfolio counselors implement for this purpose that could easily be disclosed
in the prospectus. We believe that to try to capture the various
strategies used by all of the portfolio counselors in a sentence or two could be
misleading to a shareholder. We will add disclosure to the second
paragraph of this section explaining that the fund’s assets are managed under a
system of multiple portfolio counselors and a brief description of the
system.
2. Principal
investment strategies – page 3 of the fund’s prospectus
Comment: Does the
fund consider investments in securities other than common stocks to be a
principal strategy for the fund? If so, please include in this
section.
Response: The
fund considers investing in common stocks to be its principal investment
strategy. Other strategies employed by portfolio counselors are
secondary or tertiary strategies. Some of these strategies are set
forth in the “Investment objective, strategies and risks” section of the
prospectus.
3. Investment
objective, strategies and risks – page 8 of the fund’s prospectus
Comment: Please
define the phrase “other equity-type securities” in the second paragraph of this
section.
Response: We
will modify the disclosure to include the phrase “such as preferred stocks,
convertible preferred stocks and convertible bonds” to clarify what is intended
by the phrase other equity-type securities.
4. Investment
objective, strategies and risks – page 9 of the fund’s prospectus
Comment: When
disclosing that the funds may invest in securities rated Ba1 and BB+ or below,
please refer to these securities as “junk bonds.”
Response: We
will include disclosure that such securities are sometimes referred to as “junk
bonds.”
5. Additional
investment results – page 10 of the fund’s prospectus
Comment: Please
include information for the S&P 500 as the fund’s broad based securities
index for comparative purposes. This information is required to be
presented in both the Investment results table and the Additional investment
results table.
Response: We
will include the information for the S&P 500 in the Additional investment
results table under the title “Indexes.”
The changes
described above will also be made to the fund’s retirement plan prospectus, to
the extent the change applies to that document. Thank you for your consideration
of our response to your comments.
If
you have any questions please do not hesitate to contact me at (415) 393-7110 or
Michael Triessl at (213) 615-4024.
Sincerely,
/s/ Patrick
Quan
Patrick
Quan
Secretary