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Stradley Ronon Stevens & Young, LLP
2005 Market Street, Suite 2600
Philadelphia, PA 19103
Telephone 215.564.8000
Fax 215.564.8120
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E. Taylor Brody
ebrody@stradley.com
215-564-8071
May 20, 2021
Filed via EDGAR
Ms. Jaea Hahn
Mr. Jeff Long
U.S. Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549
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Subject:
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Filings on Form N-14 for Delaware Delaware Group® Equity Funds V, Delaware Group® Global & International
Funds and Delaware Group® Income Funds (File Nos. 333-255163, 333-255164, and 333-255167) (each, a “Registrant” and together, the
“Registrants”)
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Dear Ms. Hahn:
As discussed, the Registrants hereby commit to add a statement to the following effect to their upcoming
post-effective 485(b) amendment:
In the event that a claim for indemnification against such liabilities (other than the payment by the registrant of
expenses incurred or paid by a director, officer or controlling person of the registrant in the successful defense of any action, suit or proceeding) is asserted by such director, officer or controlling person in connection with the securities
being registered, the registrant will, unless in the opinion of its counsel the matter has been settled by controlling precedent, submit to a court of appropriate jurisdiction the question whether such indemnification by it is against public policy
as expressed in the Act and will be governed by the final adjudication of such issue.
Please do not hesitate to contact me at (215) 564-8071 if you have any questions or wish to discuss this further.
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Very truly yours,
/s/ Taylor Brody
Taylor Brody
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