Daly, who won the Korean Open last month in his last tournament, matched Todd Fischer and Michael Muehr at 6-under 210. Fischer, 102nd on the PGA Tour money list as a rookie this year, shot a 68 at Del Monte, and Muehr had a 72 at Spyglass Hill.
Daly missed the cut, withdrew or was disqualified in his last seven Tour events this season.
'I've been hitting the ball really well,' Daly said. 'But anytime you win, it doesn't matter where you are -- it's good, and I think this is the toughest field the event has ever had.'
Scotland's Janice Moodie, a two-time winner on the LPGA Tour, was a stroke back after a 73. Bo Van Pelt, Curt Bryun, James McLean and Jim Thorpe also were at 5-under 211.
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