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 | | ROPES & GRAY LLP ONE INTERNATIONAL PLACE BOSTON, MA 02110-2624 617-951-7000 F 617-951-7050 BOSTON NEW YORK PALO ALTO SAN FRANCISCO TOKYO WASHINGTON, DC www.ropesgray.com |
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| December 24, 2009 | | | | |
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| | | | Johnathan Mathiesen |
| | | | (617) 951-7467 |
| | | | johnathan.mathiesen@ropesgray.com |
Securities and Exchange Commission
Division of Investment Management
100 F Street, N.E.
Washington, DC 20549
| Re: | Allianz Funds Multi-Strategy Trust (File No. 811-22167) |
Ladies and Gentleman:
On behalf of Allianz Funds Multi-Strategy Trust (the “Trust”), we are today filing, under the Securities Act of 1933, as amended, (the “1933 Act”) a registration statement on Form N-14 (the “Registration Statement”). The Registration Statement relates to the proposed acquisition by Allianz NACM International Growth Fund (the “Acquiring Fund”), a series of the Trust, of substantially all of the assets of Nicholas-Applegate International Growth Fund (the “NAIF Fund”), a series of Nicholas-Applegate Institutional Funds, and the issuance of Institutional Class shares of beneficial interest in the Acquiring Fund in connection therewith (the “Shares”), all in accordance with the terms of an Agreement and Plan of Reorganization by and among the Trust, on behalf of the Acquiring Fund, Nicholas-Applegate Institutional Funds, on behalf of the NAIF Fund, and Allianz Global Investors Fund Management LLC (the “Agreement and Plan of Reorganization”), in substantially the form included as Appendix A to the Prospectus/Proxy Statement that is part of the Registration Statement.
The Prospectus/Proxy Statement that constitutes Part A of the Registration Statement will be used in connection with a meeting of shareholders of the NAIF Fund, at which shareholders of the NAIF Fund will be asked to vote on the proposed acquisition of the NAIF Fund by the Acquiring Fund.
The Registration Statement is proposed to become effective on January 23, 2010 pursuant to Rule 488 under the 1933 Act.
No fees are required in connection with this filing. Please direct any questions you may have with respect to this filing to me (at 617-951-7467).
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| Sincerely, |
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| /s/ Johnathan Mathiesen |
| Johnathan Mathiesen, Esq. |
William Healey, Esq.
Brian Shlissel
Thomas J. Fuccillo, Esq.
Richard Kirk, Esq.
Angela Borreggine, Esq.
David C. Sullivan, Esq.
George B. Raine, Esq.
