1(212) 318-6275
rachaelschwartz@paulhastings.com
May 16, 2013
U.S. Securities and Exchange Commission
Division of Investment Management
100 F Street, N.E.
Washington, DC 20549
Re: | SunAmerica Specialty Series (the “Trust”) |
Ladies and Gentlemen:
Transmitted herewith for filing is Pre-effective Amendment No. 1 to the Registration Statement on Form N-14 for the above referenced Trust, which has been marked to show changes from the Registration Statement on Form N-14 of the Trust that was filed on April 17, 2013, in connection with the proposed reorganization of the Focused Small-Cap Growth Portfolio, a series of SunAmerica Series, Inc. into Focused Alpha Growth Fund, a series of the Trust. The Trust proposes that the filing become effective on May 17, 2013, pursuant to a request for acceleration of effectiveness submitted herewith in accordance with Rule 461 under the Securities Act of 1933.
Please call the undersigned at (212) 318-6275 with any questions or comments you may have regarding the filing. Thank you.
Very truly yours,
/s/ Rachael L. Schwartz
Rachael L. Schwartz
for PAUL HASTINGS LLP
cc: John E. McLean, Esq., SunAmerica Asset Management Corp.
Paul Hastings LLP | 75 East 55th Street | New York, NY 10022
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