Fidelity Advisor Emerging Asia Fund Class C CORRESP Correspondence with SEC

COMMENTS RECEIVED ON NOVEMBER 23, 2004

FROM CHRISTIAN SANDOE

FIDELITY ADVISOR SERIES II (File Nos. 033-06516 and 811-04707)

Fidelity Advisor Floating Rate High Income Fund, Fidelity Advisor Government Investment Fund, Fidelity Advisor High Income Fund, Fidelity Advisor High Income Advantage Fund, Fidelity Advisor Intermediate Bond Fund, Fidelity Advisor Mortgage Securities Fund, Fidelity Advisor Municipal Income Fund, Fidelity Advisor Short Fixed-Income Fund, and Fidelity Advisor Value Fund

POST-EFFECTIVE AMENDMENT NOS. 70 & 72

FIDELITY ADVISOR SERIES VIII (File Nos. 002-86711 and 811-03855)

Fidelity Advisor Diversified International Fund, Fidelity Advisor Emerging Asia Fund, Fidelity Advisor Emerging Markets Fund, Fidelity Advisor Europe Capital Appreciation Fund, Fidelity Advisor Global Equity Fund, Fidelity Advisor International Capital Appreciation Fund, Fidelity Advisor Japan Fund, Fidelity Advisor Korea Fund, Fidelity Advisor Latin America Fund, Fidelity Advisor Overseas Fund, and Fidelity Advisor Value Leaders Fund

POST-EFFECTIVE AMENDMENT NO. 77

FIDELITY BEACON STREET TRUST (File Nos. 002-64791 and 811-02933)

Fidelity Advisor Tax Managed Stock Fund and Fidelity Tax Managed Stock Fund

POST-EFFECTIVE AMENDMENT NO. 56

1. All funds (as applicable)

Performance Charts, Fee Tables, Financial Highlights, and Trustee Compensation Tables (prospectuses and statements of additional information (SAIs))

C: Please submit completed performance charts, fee tables, financial highlights, and the trustee compensation tables when the information becomes available.

R: The requested information will be faxed to you when it becomes available.

2. Fidelity Advisor Value Leaders Fund

"Front Cover" (prospectuses)

C: Is the name of the fund one or two concepts, is it meant to be "value and leaders" or "value leaders"? What does it mean?

R: The terms "value" and "leaders" in the fund's name represent one concept, value companies that are large and well-known. This concept corresponds to the fund's principal investment strategies of "investing primarily in common stocks of well-known and established companies" and "investing in securities of companies that it believes are undervalued in the marketplace."

Fidelity Advisor Series II (File Nos. 033-06516 and 811-04707), Post-Effective Amendment Nos. 70 & 72; Fidelity Advisor Series VIII (File Nos. 002-86711 and 811-03855), Post-Effective Amendment No. 77; Fidelity Beacon Street Trust (File Nos. 002-64791 and 811-02933), Post-Effective Amendment No. 56

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3. Fidelity Advisor Value Leaders Fund

"Investment Summary" (prospectuses)

"Principal Investment Strategies"

"Normally investing at least 80% of assets in blue chip companies (companies whose stock is included in the Standard & Poor's 500 Index (S&P 500) or the Dow Jones Industrial Average (DJIA), and companies with market capitalizations of at least $1 billion if not included in either index)."

C: There appears to be two criteria for the fund's 80% name test, a set of indices and companies with market capitalizations of at least $1 billion. The second criteria doesn't seem to be anything that would get the fund near blue chip or seen as a leader. How does this fit with the fund's name?

R: We note that the fund does not have a name test policy, as neither term in its name triggers application of the Name Test Rule. The fund does, however, have a policy of investing at least 80% of assets in blue chip companies, based upon FMR's definition of "blue chip." The fund also has a principal investment strategy of "[n]ormally investing primarily in common stocks of well-known and established companies." While the S&P 500 and DJIA are commonly regarded as indices of stocks of companies that are "well-known and established," the fund could invest in stocks of similar quality not included in either index. We believe that identifying a market capitalization range of at least $1 billion, when considered in connection with the fund's principal investment strategy of investing primarily in the common stocks of well-known and established companies, provides a reasonable approach for identification of "blue chip companies."

4. Fidelity Advisor High Income Advantage Fund, Fidelity Advisor High Income Fund, Fidelity Advisor Global Equity Fund, Fidelity Advisor Diversified International Fund, Fidelity Advisor Latin America Fund, Fidelity Advisor Korea Fund, Fidelity Advisor Overseas Fund, and Fidelity Advisor Europe Capital Appreciation Fund

"Investment Summary" (prospectuses)

"Principal Investment Risks"

(Fidelity Advisor High Income Advantage Fund, Fidelity Advisor High Income Fund, Fidelity Advisor Global Equity Fund, and Fidelity Advisor Diversified International Fund)

(Fidelity Advisor Latin America Fund, Fidelity Advisor Korea Fund, Fidelity Advisor Overseas Fund, and Fidelity Advisor Europe Capital Appreciation Fund)

"Foreign Exposure. Foreign markets,particularly emerging markets, can be more volatile than the U.S. market due to increased risks of adverse issuer, political, regulatory, market, or economic developments and can perform differently from the U.S. market. Emerging markets can be subject to greater social, economic, regulatory, and political uncertainties and can be extremely volatile."

C: The Staff would like emerging markets added as a strategy under the "Principal Investment Strategies" heading.

R: Though the non-U.S. securities in which the funds invest may include foreign issuers in both developed and emerging markets, these funds currently do not have a principal investment strategy of investing in emerging markets.

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5. Fidelity Advisor Value Fund, Fidelity Advisor Diversified International Fund, Fidelity Advisor Emerging Asia Fund, Fidelity Advisor Emerging Markets Fund, Fidelity Advisor Europe Capital Appreciation Fund, Fidelity Advisor Global Equity Fund, Fidelity Advisor International Capital Appreciation Fund, Fidelity Advisor Japan Fund, Fidelity Advisor Korea Fund, Fidelity Advisor Latin America Fund, Fidelity Advisor Overseas Fund, Fidelity Tax Managed Stock Fund, and Fidelity Advisor Tax Managed Stock Fund

"Investment Summary" (prospectuses)

"Principal Investment Strategies"

C: What is the fund's market capitalization strategy?

R: The funds do not have a principal investment strategy of investing in securities of companies with a particular market capitalization.

6. Fidelity Advisor Global Equity Fund

"Investment Summary" (prospectuses)

"Principal Investment Strategies"

"Allocating investments across countries and regions considering the size of the market in each country and region relative to the size of the world market as a whole."

C: The Staff noted that the Name Test Rule makes reference to what would be expected of a global fund. The Staff suggests changing the above disclosure to say "Allocating investments acrossseveral countries and regions . . ."

R: We would be happy to discuss the Staff's comment further, but are hesitant to make this change, as it could be misleading. The term "several" is commonly understood to mean three or four, and the fund invests in a far greater number of countries and regions. For example, as of April 30, 2004, the fund was investing in approximately 25 countries and regions.

7. Fidelity Advisor Floating Rate High Income Fund

"Investment Summary" (prospectuses)

"Principal Investment Risks"

"Impairment of Collateral. A floating rate loan may not be fully collateralized which may cause the floating rate loan to decline significantly in value."

C: If a floating rate loan may not be fully collateralized, how can the collateral be impaired?

R: Collateral impairment is the risk that the value of the collateral for a floating rate loan will be insufficient in the event that a borrower defaults. Although the terms of a floating rate loan generally require that the collateral at issuance have a value at least equal to 100% of the amount of such loan, the value of the collateral may decline subsequent to the purchase of the loan, causing the loan to be undercollaterlized and to decrease in value.

8. Fidelity Advisor Floating Rate High Income Fund, Fidelity Advisor High Income Fund, and Fidelity Advisor High Income Advantage Fund

"Investment Summary" (prospectuses)

"Principal Investment Strategies"

C: The Staff believes that a discussion of the fund's maturity policy should be included in this section.

R: The funds do not have a principal investment strategy to invest in securities of a particular maturity.

9. Fidelity Advisor High Income Advantage Fund

"Investment Summary" (prospectuses)

"Principal Investment Risks"

C: The Staff notes that although the placement of the "stock market volatility" risk disclosure is consistent with other Fidelity funds' prospectuses, it seems odd that it would be the first and seemingly most important risk in the context of this fund, which can invest up to 20% in common stocks.

R: Item 2(c)(1)(i) of Form N-1A does not require or suggest that we should specify the principal risks of investing in the fund in any particular order of perceived importance. As market conditions change during the life of a prospectus, certain risks may become more prominent than others, and therefore become more likely to affect adversely the fund's net asset value, yield, or total return. We are concerned that ranking risks as of the effective date of a prospectus may not be a meaningful ranking for the life of the prospectus and therefore have not modified our disclosure.

10. Fidelity Advisor Intermediate Bond Fund and Fidelity Advisor Short Fixed-Income Fund

"Investment Summary" (prospectuses)

"Principal Investment Strategies"

"Normally investing at least 80% of assets in investment-grade debt securities (those of medium and high quality) of all types and repurchase agreements for those securities."

C: The Staff believes that the fund should invest 80% in bonds, which can then be defined as debt securities or investment-grade debt securities, as applicable.

R: We believe that any requirement under Rule 35d-1 of the 1940 Act for the fund to have a policy to invest 80% in bonds is met by its policy to invest 80% in debt securities. In this regard, as previously discussed with the Staff, we continue to take the position we have taken historically, which is that the term "bond" suggests debt securities of all types (see Stan Griffith's June 21, 1990 letter to David Wills, then Branch Chief of the SEC's Division of Investment Management). We note that the Commission, when adopting Rule 35d-1, did not elaborate on the types of debt securities suggested by the term "bond." Moreover, we believe that complying with the Staff's request that the fund adopt a policy of investing in "bonds" and then defining bonds to be the types of securities currently referenced in the fund's 80% policy differs from the current disclosure in form only, not in substance, and reflects an acknowledgment that the substance of the fund's 80% policy is acceptable. Accordingly, we believe that the fund's name and 80% policy are consistent with Rule 35d-1 and have not revised the disclosure as suggested.

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11. Fidelity Advisor Intermediate Bond Fund and Fidelity Advisor Short Fixed-Income Fund

"Investment Summary" (prospectuses)

"Principal Investment Risks"

"Foreign Exposure.Entities located in foreign countries can be affected by adverse political, regulatory, market, or economic developments in those countries."

C: The Staff believes that the above risk disclosure found under the sub-heading "Principal Investment Risks" in the "Investment Summary" section should have a corresponding strategy identified under the sub-heading "Principal Investment Strategies" in the "Investment Summary" section.

R: Each fund has a principal investment strategy of investing in investment-grade debt securities of all types. These debt securities can include debt issued by foreign issuers or by U.S. entities with substantial foreign operations, and debt for which a foreign entity has provided credit support. The fund's investment in these particular types of debt securities does not rise to the level of a "Principal Investment Strategy," but these types of debt securities may nonetheless present a "Principal Investment Risk" of foreign exposure which we believe should be disclosed. Accordingly, we have not added the disclosure as the Staff has suggested.

12. Fidelity Advisor Mortgage Securities Fund

"Investment Summary" (prospectuses)

"Principal Investment Strategies"

"Normally investing at least 80% of assets in investment-grade mortgage-related securities (those of medium and high quality) and repurchase agreements for those securities."

C: What does the term mortgage-related securities mean? Does it mean securities with economic characteristics similar to the name?

R: The term "mortgage-related securities" is summarized in the "Investment Details" section of the prospectus under the heading "Mortgage Securities" in the "Description of Principal Security Types" section, as well as in the SAI under the same heading within the "Investment Policies and Limitations" section.

13. Fidelity Advisor Floating Rate High Income Fund, Fidelity Advisor Government Investment Fund, Fidelity Advisor High Income Fund, Fidelity Advisor High Income Advantage Fund, Fidelity Advisor Intermediate Bond Fund, Fidelity Advisor Mortgage Securities Fund, Fidelity Advisor Municipal Income Fund, and Fidelity Advisor Short Fixed-Income Fund

"Investment Summary" (prospectuses)

"Principal Investment Risks"

C: The Staff believes that corresponding credit risk disclosure should be added under the sub-heading "Principal Investment Risks" in the "Investment Summary" section to reflect the risks involved in investing in debt securities.

R: We direct the Staff's attention to the disclosure concerning "Issuer-Specific Changes" under the heading "Principal Investment Risks" in the "Investment Summary" section. This disclosure summarizes the risks associated with changes in an issuer's credit quality by recognizing that, for reasons specific to a particular issuer, "[t]he value of an individual security or particular type of security can be more volatile than the market as a whole and can perform differently from the value of the market as a whole." For Fidelity Advisor Floating Rate High Income Fund, Fidelity Advisor High Income Fund, and Fidelity Advisor High Income Advantage Fund the disclosure also summarizes the credit risk associated with investments in lower quality debt securities. Many issuer-specific risk factors can impact an issuer's credit quality and cause the value or credit quality of its securities to decline when the market as a whole may be rising, including changes in the financial condition of a particular issuer and changes in the economic and political environment that may impact issuers of a particular type.

14. Fidelity Advisor Floating Rate High Income Fund

"Performance" (prospectuses)

"Average Annual Returns"

C: Why is the Credit Suisse First Boston (CSFB) Leveraged Loan Index Plus an appropriate broad based index? The Staff questions whether this index is broad based because it is more leveraged and not floating. The Staff asks what other floating rate funds use as their broad based indexes?

R: The Credit Suisse First Boston (CSFB) Leveraged Loan Index is a market-weighted index designed to represent the investable universe of the U.S. Dollar-denominated leveraged (i.e., floating rate) loan market. CSFB Leveraged Loan Index is also used by the Eaton Vance Floating-Rate Fund and Franklin Templeton's Franklin Floating Rate Daily Access Fund. In addition, in compliance with Item 2 of Form N-1A, the administrator of the index (CSFB) is not affiliated with the fund. (Please note there is a typographical error in the current name of the index which will be addressed in the next filing.)

15. All funds except Fidelity Advisor Value Fund, Fidelity Advisor Emerging Markets Fund, and Fidelity Advisor Value Leaders Fund

"Performance" (prospectuses)

C: Add a statement that the purpose of the disclosure is to demonstrate the risk of investing in the fund pursuant to Item 2(c)(2)(i) of Form N-1A.

R: To address the Staff's concern, we will add the following disclosure:

"The following information is intended to help you understand the risks of investing in the fund."

16. Fidelity Advisor Japan Fund, Fidelity Advisor Diversified International Fund, and Fidelity Advisor High Income Advantage Fund

"Performance" (prospectuses)

"Average Annual Returns"

C: Disclose each class' inception date because you are showing "life of class" performance data.

R: We will add each class' inception date in the next filing.

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17. Class A, T, B, and C of all Advisor funds, Institutional Class of Fidelity Advisor High Income Fund, Fidelity Advisor Emerging Markets Fund, Fidelity Advisor Floating Rate High Income Fund, Fidelity Advisor Europe Capital Appreciation Fund, Fidelity Advisor Emerging Asia Fund, Fidelity Advisor Diversified International Fund, Fidelity Advisor Global Equity Fund, Fidelity Advisor International Capital Appreciation Fund, Fidelity Advisor Japan Fund, Fidelity Advisor Korea Fund, Fidelity Advisor Latin America Fund, Fidelity Advisor Overseas Fund, and Fidelity Advisor High Income Advantage Fund, and the retail class of Advisor Floating Rate High Income Fund

"Fee Table" (prospectuses)

C: The "Shareholder fees" and "Annual operating expenses" information should be presented as one table with all footnotes following the table in its entirety. The Staff believes that inserting footnotes after the "Shareholder fees" information results in two tables instead of one.

R: As we have previously discussed with the Staff, we believe that the information included under the subheadings "Shareholder fees" and "Annual operating expenses" in the "Fee Table" section of the prospectus is presented in a manner consistent with Item 3 of Form N-1A. The footnotes that support the information under each subheading are provided in the closest proximity possible to that information to facilitate shareholder understanding of the information presented. We note that General Instruction C.1(a) to Form N-1A states that a fund should use document design techniques that promote effective communication, and we believe this format most effectively communicates the information presented.

18. All funds

"Fee Table" (prospectuses)

C: The disclosure following the fee table concerning the reimbursement of certain expenses should be set forth as a footnote to the fee table rather than text pursuant to General Instruction C.3(b).

R: The disclosure at issue follows the fee table and a footnote disclosing expense reimbursement arrangements, if any. The disclosure relates both to the total annual operating expenses in the fee table as well as to the footnote disclosing the expense reimbursement arrangements, if any, and the actual annual operating expenses that include the effect of the expense reimbursements. We believe that presenting disclosure in narrative form rather than in an additional footnote to the fee table, or as additional disclosure in the expense reimbursement arrangement footnote, if any, provides a clearer presentation for the shareholder. We believe that the disclosure complies with the requirements of Form N-1A and, accordingly, we propose not to modify it.

19. Fidelity Advisor Japan Fund, Fidelity Advisor Latin America Fund, Fidelity Advisor Korea Fund, Fidelity Tax Managed Stock Fund, Fidelity Advisor Tax Managed Stock Fund, Fidelity Advisor Global Equity Fund, Fidelity Advisor Overseas Fund, Fidelity Advisor Value Fund, Fidelity Advisor Diversified International Fund, Fidelity Advisor Emerging Asia Fund, Fidelity Advisor International Capital Appreciation Fund, Fidelity Advisor Europe Capital Appreciation Fund, Fidelity Advisor Value Leaders Fund, Fidelity Advisor Emerging Markets Fund, Fidelity Advisor Short Fixed-Income Fund, Fidelity Advisor Mortgage Securities Fund, Fidelity Advisor Municipal Income Fund, Fidelity Advisor Intermediate Bond Fund, Fidelity Advisor High Income Advantage Fund, Fidelity Advisor High Income Fund, Fidelity Advisor Floating Rate High Income Fund, and Fidelity Advisor Government Investment Fund

"Investment Details" (prospectuses)

"Principal Investment Strategies"

(Fidelity Advisor Japan Fund, Fidelity Advisor Latin America Fund, Fidelity Advisor Korea Fund, Fidelity Tax Managed Stock Fund, Fidelity Advisor Tax Managed Stock Fund, Fidelity Advisor Global Equity Fund, Fidelity Advisor Overseas Fund, Fidelity Advisor Value Fund, Fidelity Advisor Diversified International Fund, Fidelity Advisor Emerging Asia Fund, Fidelity Advisor International Capital Appreciation Fund, Fidelity Advisor Europe Capital Appreciation Fund, Fidelity Advisor Value Leaders Fund, and Fidelity Advisor Emerging Markets Fund)

"In addition to the principal investment strategies discussed above, FMR may lend the fund's securities to broker-dealers or other institutions to earn income for the fund.

FMR may also use various techniques, such as buying and selling futures contracts and exchange traded funds, to increase or decrease the fund's exposure to changing security prices or other factors that affect security values. If FMR's strategies do not work as intended, the fund may not achieve its objective."

(Fidelity Advisor Short Fixed-Income Fund, Fidelity Advisor Mortgage Securities Fund, Fidelity Advisor Municipal Income Fund, and Fidelity Advisor Intermediate Bond Fund)

"In addition to the principal investment strategies discussed above, FMR may use various techniques, such as buying and selling futures contracts, swaps, and exchange traded funds, to increase or decrease the fund's exposure to changing security prices, interest rates, or other factors that affect security values. FMR may invest the fund's assets in [investment-grade/for municipal fund: municipal] debt securities by investing in other funds. If FMR's strategies do not work as intended, the fund may not achieve its objective."

(Fidelity Advisor High Income Advantage Fund and Fidelity Advisor High Income Fund)

"In addition to the principal investment strategies discussed above, FMR may use various techniques, such as buying and selling futures contracts and exchange traded funds, to increase or decrease the fund's exposure to changing security prices, interest rates, or other factors that affect security values. FMR may invest the fund's assets in investment-grade debt securities by investing in other funds. If FMR's strategies do not work as intended, the fund may not achieve its objective."

(Fidelity Advisor Floating Rate High Income Fund)

"In addition to the principal investment strategies discussed above, FMR may use various techniques, such as buying and selling futures contracts and exchange traded funds, to increase or decrease the fund's exposure to changing security prices, interest rates, or other factors that affect security values. If FMR's strategies do not work as intended, the fund may not achieve its objective."

(Fidelity Advisor Government Investment Fund)

"In addition to the principal investment strategies discussed above, FMR may use various techniques, such as buying and selling futures contracts, swaps, and exchange traded funds, to increase or decrease the fund's exposure to changing security prices, interest rates, or other factors that affect security values. If FMR's strategies do not work as intended, the fund may not achieve its objective."

C: The Staff requests that we add these techniques to the risk/return summary, or if they are not principal, delete them from this section.

R: Item 2 of Form N-1A requires that the risk/return summary be limited to disclosure of the fund's "principal" investment strategies and "principal" risks. The techniques identified in the disclosure at issue are not currently considered "principal" strategies for the funds, and therefore we have not added them to the risk/return summary.

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We believe that the phrase "In addition to the principal investment strategies discussed above," added to disclosure pursuant to the Staff's previous comments, adequately conveys that the strategies that follow are not currently considered principal. In addition, General Instruction C.(3)(b) permits a fund to include in its prospectus (except in the Item 2 and Item 3 sections of the prospectus) information that is not otherwise required, provided the information is not incomplete, inaccurate, or misleading, and the disclosure does not obscure or impede understanding of the information that is required to be included. We feel the disclosure provides shareholders with additional significant information about the funds' strategies.

20. Fidelity Advisor Value Leaders Fund, Fidelity Advisor Value Fund, Fidelity Tax Managed Stock Fund, Fidelity Advisor Tax Managed Stock Fund, Fidelity Advisor High Income Fund, Fidelity Advisor High Income Advantage Fund, Fidelity Advisor Japan Fund, Fidelity Advisor Europe Capital Appreciation Fund, Fidelity Advisor Diversified International Fund, Fidelity Advisor Overseas Fund, Fidelity Advisor Global Equity Fund, Fidelity Advisor Korea Fund, and Fidelity Advisor Latin America Fund

"Investment Details" (prospectuses)

"Principal Investment Risks"

(Fidelity Advisor Value Leaders Fund, Fidelity Advisor Value Fund, Fidelity Tax Managed Stock Fund, Fidelity Advisor Tax Managed Stock Fund, Fidelity Advisor High Income Fund, Fidelity Advisor High Income Advantage Fund, and Fidelity Advisor Japan Fund)

"Foreign Exposure. Foreign securities, foreign currencies, and securities issued by U.S. entities with substantial foreign operations can involve additional risks relating to political, economic, or regulatory conditions in foreign countries. These risks include fluctuations in foreign currencies; withholding or other taxes; trading, settlement, custodial, and other operational risks; and the less stringent investor protection and disclosure standards of some foreign markets. All of these factors can make foreign investments, especially those in emerging markets, more volatile and potentially less liquid than U.S. investments. In addition, foreign markets can perform differently from the U.S. market."

(Fidelity Advisor Europe Capital Appreciation Fund, Fidelity Advisor Diversified International Fund, Fidelity Advisor Overseas Fund, Fidelity Advisor Global Equity Fund, Fidelity Advisor Korea Fund, and Fidelity Advisor Latin America Fund)

Investing in emerging markets can involve risks in addition to and greater than those generally associated with investing in more developed foreign markets. The extent of economic development; political stability; market depth, infrastructure, and capitalization; and regulatory oversight can be less than in more developed markets. Emerging market economies can be subject to greater social, economic, regulatory, and political uncertainties. All of these factors can make emerging market securities more volatile and potentially less liquid than securities issued in more developed markets."

C: The Staff requests that we add a statement relating to emerging markets under the "Principal Investment Strategies" heading.

21. Fidelity Advisor Overseas Fund, Fidelity Advisor Emerging Markets Fund, Fidelity Advisor Europe Capital Appreciation Fund, Fidelity Advisor Global Equity Fund, Fidelity Advisor Japan Fund, Fidelity Advisor Korea Fund, Fidelity Advisor Latin America Fund, and Fidelity Advisor Emerging Asia Fund

"Investment Details" (prospectuses)

"Country or Geographic Region"

"Country or Geographic Region

FMR considers a number of factors to determine whether an investment is tied economically to a particular country or region including: the source of government guarantees (if any); the primary trading market; the issuer's domicile, sources of revenue, and location of assets; whether the investment is included in an index representative of a particular country or region; and whether the investment is exposed to the economic fortunes and risks of a particular country or region."

C: The Staff notes that the standards for determining whether an investment is tied economically to a particular country or region appear to be vague.

R: We note that additional detail regarding the factors FMR considers appears under the heading "Country or Geographic Region" in the "Investment Policies and Limitations" section of the funds' SAI. A bright line test is not necessary for determining whether an investment is tied economically to a particular country or region. This point is illustrated in the adopting release for Rule 35d-1 of the Investment Company Act of 1940 (1940 Act), which recognized that the Rule is intended to allow a fund the flexibility to invest in investments that do not meet the specific criteria but "expose the fund's assets to the economic fortunes and risks of the country or geographic region indicated by its name."

22. Fidelity Advisor Emerging Markets Fund, Fidelity Advisor Floating Rate High Income Fund, Fidelity Advisor Emerging Asia Fund, Fidelity Advisor Korea Fund, Fidelity Advisor Latin America Fund, and Fidelity Advisor Value Leaders Fund

"Investment Details" (prospectuses)

"Principal Investment Strategies"

"Because the fund is considered non-diversified, FMR may invest a significant percentage of the fund's assets in a single issuer."

C: The Staff noted that it does not see non-diversification risk disclosure in this section.

R: The following disclosure appears under the heading "Principal Investment Risks": "Because FMR may invest a significant percentage of the fund's assets in a single issuer, the fund's performance could be closely tied to that one issuer and could be more volatile than the performance of more diversified funds."

23. Fidelity Advisor Emerging Asia Fund, Fidelity Advisor Value Leaders Fund, Fidelity Advisor International Capital Appreciation Fund, Fidelity Advisor Value Fund, Fidelity Advisor Tax Managed Stock Fund, Fidelity Tax Managed Stock Fund, Fidelity Advisor Emerging Markets Fund, Fidelity Advisor Diversified International Fund, Fidelity Advisor Overseas Fund, Fidelity Advisor Europe Capital Appreciation Fund, Fidelity Advisor Korea Fund, Fidelity Advisor Japan Fund, Fidelity Advisor High Income Advantage Fund, Fidelity Advisor High Income Fund, Fidelity Advisor Latin America Fund, and Fidelity Advisor Global Equity Fund

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"Investment Details" (prospectuses)

"Principal Investment Risks"

"Issuer-Specific Changes. Changes in the financial condition of an issuer or counterparty . . .The value of securities of smaller, less well-known issuers can be more volatile than that of larger issuers."

C: If investing in smaller, less well-known issuers is a strategy of the fund, then it should be listed as a principal investment strategy in the Item 4 section of the prospectuses with corresponding changes made to the Item 2 risk/return summary section of the prospectuses.

R: Investing in smaller, less well-known issuers is not currently a principal investment strategy of these funds.

24. Fidelity Advisor Emerging Markets Fund

"Investment Details" (prospectuses)

"Principal Investment Strategies"

"FMR normally invests at least 80% of the fund's assets in securities of issuers in emerging markets and other investments that are tied economically to emerging markets. Emerging markets include countries that have an emerging stock market as defined by S&P, countries or markets with low- to middle-income economies as classified by the World Bank, and other countries or markets with similar emerging characteristics. For example, countries in the Morgan Stanley Capital International Emerging Markets (MSCI EM) Index and Hong Kong are considered to be emerging. Emerging markets tend to have relatively low gross national product per capita compared to the world's major economies and may have the potential for rapid economic growth. FMR normally invests the fund's assets primarily in common stocks."

C: The Staff is surprised that Hong Kong would be considered emerging.

R: The fund has a name test policy of normally investing at least 80% of its assets in securities of issuers in emerging markets and other investments that are tied economically to emerging markets. The SEC has stated that a fund may use any reasonable definition of the terms used in its name and should define the terms used in its name in discussing its investment objectives and strategies in the prospectus. See Name Test Rule Adopting Release Footnote 43. Accordingly, in defining the terms used in the fund's name test policy we disclose that Hong Kong may be considered emerging.

25. Fidelity Advisor Emerging Markets Fund

"Investment Details" (prospectuses)

"Description of Principal Security Types"

"Debt securities are used by issuers to borrow money. The issuer usually pays a fixed, variable, or floating rate of interest, and must repay the amount borrowed, usually at the maturity of the security. Some debt securities, such as zero coupon bonds, do not pay current interest but are sold at a discount from their face values. Debt securities include corporate bonds, government securities, repurchase agreements, mortgage and other asset-backed securities, loans and loan participations, and other securities that FMR believes have debt-like characteristics, including hybrids and synthetic securities."

C: The Staff notes that there is no strategy to invest in debt securities under the "Principal Investment Strategies" heading.

R: The fund has a principal investment strategy to invest at least 80% of its assets in securities of issuers in emerging markets and other investments that are tied economically to emerging markets. The fund's investments in "emerging markets securities" can include both equity and debt. Therefore, we think it is helpful to shareholders to include the "debt securities" description, in addition to the "equity securities" description.

26. Fidelity Advisor Korea Fund and Fidelity Advisor Latin America Fund

"Investment Details" (prospectuses)

"Principal Investment Strategies"

(Fidelity Advisor Korea Fund)

"FMR may invest up to 35% of the fund's total assets in any industry that accounts for more than 20% of the Korean market, as represented by an index determined by FMR to be an appropriate measure of the market. FMR intends to measure the percentage of the index represented by each industry no less frequently than once per month.[As of October 31, 2004, [Name(s) of Industry(ies) > 20% (with rounding) of Market-Specific Index] accounted for approximately [__%] [,/and] [__%] [, and __%] [, respectively,] of the KOSPI.]"

(Fidelity Advisor Latin America Fund)

"FMR may invest up to 35% of the fund's total assets in any industry that accounts for more than 20% of the Latin American market as a whole, as represented by an index determined by FMR to be an appropriate measure of the market. FMR intends to measure the percentage of the index represented by each industry no less frequently than once per month.As of October 31, 2004, [Name(s) of Industry(ies)] accounted for approximately [__%] [,/and] [__%] [, and __%] [, respectively,] of the MSCI EM.]"

C: Explain how this policy is consistent with Section 8(b)(1) of the 1940 Act as evidenced by the First Australia no-action letter. It seems that the fund could change the index at will.

R: As you know, Fidelity had numerous discussions with the SEC Staff in 1999 before this form of fundamental concentration policy was implemented for any of the Fidelity funds. The Fidelity form of policy differs from the policy at issue in the First Australia no-action letter in one respect: the Fidelity funds do not name their benchmark index as part of the fundamental policy. As a result of conversations with the Staff, we are comfortable that the funds' concentration policies nevertheless are consistent with Section 8(b)(1) of the 1940 Act. We specifically discussed with the Staff that the Fidelity funds' benchmark indexes were not a part of their fundamental policies. We explained our concern about naming an index in part of a fundamental policy when at any time an index provider may discontinue the index, stop publishing it, or change the composition of the index. We were advised orally that inclusion of the index name in the fundamental policy was not required; instead it was only one factor in determining if Section 8(b) were satisfied. Currently, each fund uses a cap-weighted index designed by its provider to reflect the performance of the local equity market, and FMR believes the indexes are appropriate measures of the funds' local markets, based on index characteristics including the percentage of the total market capitalization covered, economic sector and industry representation, and the securities that make up each index. FMR could use different indexes or additional indexes to represent the local markets in the future, but only if those indexes were determined to be appropriate based on index characteristics.

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27. Fidelity Advisor Floating Rate High Income Fund

"Investment Details" (prospectuses)

"Principal Investment Strategies"

"FMR normally invests at least 80% of the fund's assets in floating rate loans and other floating rate securities. FMR defines floating rate securities as floating rate loans, other floating rate debt securities, money market securities of all types, repurchase agreements, and shares of money market and short-term bond funds. Many floating rate loans are lower-quality. FMR may invest in companies whose financial condition is troubled or uncertain and that may be involved in bankruptcy proceedings, reorganizations, or financial restructurings."

C: The Staff would like an explanation regarding why money market securities of all types count as floating rate securities.

R: The fund has a name test policy of normally investing at least 80% of its assets in floating rate loans and other floating rate securities. The SEC has stated that a fund may use any reasonable definition of the terms used in its name and should define the terms used in its name in discussing its investment objectives and strategies in the prospectus. See Name Test Rule Adopting Release Footnote 43. Accordingly, we disclose that "FMR defines floating rate securities as floating rate loans, other floating rate debt securities, money market securities of all types, repurchase agreements, and shares of money market and short-term bond funds." Footnote 13 to the Adopting Release for Rule 35d-1 of the 1940 Act explains that the Rule's 80% requirement applies to the fund's "investments" (as opposed to the narrower term "securities"), and therefore in appropriate circumstances a fund can include in its 80% basket an investment with "economic characteristics similar to the securities included in that basket." We believe it is reasonable to treat all money market instruments, including repurchase agreements, as floating rate securities, whether or not they have variable coupons, because their short maturities give them economic characteristics (yield and price) comparable to floating rate securities.

28. Fidelity Advisor Intermediate Bond Fund, Fidelity Advisor Short Fixed-Income Fund, Fidelity Advisor Government Investment Fund, Fidelity Advisor Mortgage Securities Fund, and Fidelity Advisor Floating Rate High Income Fund

"Investment Details" (prospectuses)

"Principal Investment Strategies"

(Fidelity Advisor Intermediate Bond Fund, Fidelity Advisor Short Fixed-Income Fund, Fidelity Advisor Government Investment Fund, and Fidelity Advisor Mortgage Securities Fund)

"Prepayment.The ability of an issuer of a debt security to repay principal prior to a security's maturity can cause greater price volatility if interest rates change."

(Fidelity Advisor Floating Rate High Income Fund)

"Prepayment. The ability of an issuer of a debt security to repay principal prior to a security's maturity can limit the potential for gains when the credit quality of the issuer improves."

C: Does the prepayment risk disclosure relate primarily to callout risk or to mortgage securities? If the risk relates to mortgage securities add this as a strategy under the "Principal Investment Strategies" heading.

R: Though this risk disclosure could apply to mortgage securities as well as other types of debt securities, the funds that have principal investment strategies of investing in mortgage securities already have the requisite investment strategy disclosure, and therefore we have not added extra disclosure.

29. Fidelity Advisor Mortgage Securities Fund, Fidelity Advisor Government Investment Fund, Fidelity Advisor Short Fixed-Income Fund, and Fidelity Advisor Intermediate Bond Fund

"Investment Details" (prospectuses)

"Principal Investment Strategies"

". . . In determining a security's maturity for purposes of calculating the fund's average maturity, an estimate of the average time for its principal to be paid may be used. This can be substantially shorter than its stated maturity."

C: Is the disclosure applicable to all bonds or just callable or mortgage backed securities? Add disclosure regarding why the calculated maturity may be substantially shorter than its stated maturity.

R: The disclosure referred to by the Staff is applicable to any bond that contains a maturity shortening device such as a call, refunding, or redemption provision. Using a security's weighted average life, effective maturity, or call date in the calculation would result in a shorter weighted average maturity. We do not feel that additional disclosure is necessary.

30. Fidelity Advisor Mortgage Securities Fund an Fidelity Advisor Intermediate Bond Fund

"Investment Details" (prospectuses)

"Principal Investment Strategies"

"To earn additional income for the fund, FMR may use a trading strategy that involves selling (or buying) mortgage securities and simultaneously agreeing to purchase (or sell) mortgage securities on a later date at a set price. This trading strategy may increase interest rate exposure and result in an increased portfolio turnover rate which increases transaction costs and may increase taxable gains."

C: In the above referenced disclosure are we referring to buying and selling the same security or different ones, i.e. repos or dollar rolls? Confirm whether the disclosure is only applicable to mortgage securities and not other types of fixed income investments.

R: The disclosure at issue is meant to cover only mortgage dollar rolls and reverse mortgage dollar rolls.

31. All funds

"Fund Management" (prospectuses)

(All funds)

"As the manager, FMR has overall responsibility fordirecting the fund's investments and handling its business affairs."

(Fidelity Advisor International Capital Appreciation Fund, Fidelity Advisor Value Leaders Fund, Fidelity Advisor Floating Rate High Income Fund, Fidelity Advisor Europe Capital Appreciation Fund, Fidelity Advisor Emerging Markets Fund, Fidelity Advisor Overseas Fund, Fidelity Advisor Value Fund, Fidelity Advisor Diversified International Fund, Fidelity Advisor Tax Managed Stock Fund, Fidelity Tax Managed Stock Fund, Fidelity Advisor Global Equity Fund, Fidelity Advisor Latin America Fund, Fidelity Advisor High Income Fund, and Fidelity Advisor High Income Advantage Fund)

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"FMR Co., Inc. (FMRC) serves as a sub-adviser for the fund. FMRC has day-to-day responsibility forchoosing investments for the fund."

(Fidelity Advisor Intermediate Bond Fund, Fidelity Advisor Municipal Income Fund, Fidelity Advisor Mortgage Securities Fund, Fidelity Advisor Government Investment Fund, and Fidelity Advisor Short Fixed-Income Fund)

"Fidelity Investments Money Management, Inc. (FIMM), at One Spartan Way, Merrimack, New Hampshire 03054, serves as a sub-adviser for the fund. FIMM has day-to-day responsibility forchoosing investments for the fund."

(Fidelity Advisor Emerging Asia Fund and Fidelity Advisor Korea Fund)

"Fidelity International Investment Advisors (FIIA), at Pembroke Hall, 42 Crow Lane, Pembroke HM19, Bermuda, serves as a sub-adviser for the fund. As of September 28, 2004, FIIA had approximately $17.9 billion in discretionary assets under management. Currently, FIIA has day-to-day responsibility forchoosing investments for the fund."

(Fidelity Advisor Japan Fund)

"Fidelity Investments Japan Limited (FIJ), at Shiroyama JT Trust Tower, 3-1, Toranomon 4-chome, Minato-ku, Tokyo, Japan 105-6019, serves as a sub-adviser for the fund. As of September 28, 200, FIJ had approximately $42.1 billion in discretionary assets under management. Currently, FIJ has day-to-day responsibility forchoosing investments for the fund."

C: Clarify the difference between directing and choosing the fund's investments.

R: Under the terms of the funds' management contracts, FMR acts as the funds' investment adviser and, subject to the supervision of the Board of Trustees, has overall responsibility for directing the investments of the funds in accordance with each fund's investment objective, policies, and limitations. "Directing" investments includes choosing the funds' investments and handling business affairs for the funds. FMR may choose a fund's investments on a daily basis or may appoint an affiliated sub-adviser to do so.

32. Fidelity Advisor Value Fund

"Prior Performance of a Similar Fund" (prospectuses)

". . . Performance of other funds and accounts is not included due to factors such as differences in their policies and/or portfolio management strategies and/or because these accounts are not mutual funds."

C: The Staff believes that while excluding performance of other funds or accounts for differing policies or portfolio management strategies is acceptable, excluding performance because other accounts are not mutual funds is not a good enough reason to exclude their performance under the Nicholas Applegate no-action letter.

R: In Nicholas-Applegate Mutual Funds (pub. avail. Aug. 6, 1996), the Staff indicated that an adviser may exclude the performance of certain substantially similar funds and accounts so long as such exclusion would not cause the disclosed performance to be misleading. Although our selection of the Fidelity Value Fund fully meets the standard expressed in the no-action letter, our disclosure in the prospectus refers to the more selective standard that we used in selecting those funds, i.e., that the objectives and policies of the funds are substantially identical. The Staff has previously indicated that it is "FMR's call" to use this higher standard in selecting related funds, provided we include certain disclosure as agreed upon with the Staff. Using this standard, the differences in policies and/or portfolio management strategies preclude presentation of managed accounts in the disclosure.

33. Fidelity Advisor High Income Fund, Fidelity Advisor High Income Advantage Fund, Fidelity Advisor Intermediate Bond Fund, Fidelity Advisor Mortgage Securities Fund, and Fidelity Advisor Short Fixed-Income Fund

"Investment Policies and Limitations" (SAI)

"For purposes of each of Advisor High Income's, Advisor High Income Advantage's, Advisor Intermediate Bond's, Advisor Mortgage Securities', and Advisor Short Fixed-Income's concentration limitation discussed above, with respect to the fund's investments in Fidelity Ultra-Short Central Fund, FMR treats the issuers of the underlying securities owned by Fidelity Ultra-Short Central Fund as the issuer of Fidelity Ultra-Short Central Fund."

C: The Staff notes that the disclosure concerning the "look through" policy is confusing and needs to be stated more clearly.

R: When read in conjunction with each fund's fundamental concentration policy we think it is clear that the disclosure is intended to recite the funds' "look through" policy. We are comfortable with the current disclosure, which has been in use for a number of years, and would be hesitant to make a change to the disclosure because we would not want to suggest it applies differently when the policy itself has not changed.

34. All funds

"Board Approval of Existing Investment Advisory Contracts" (SAIs)

C: The Staff believes that consistent with the second sentence of the Instruction to Item 12(b)(10) of Form N-1A, additional disclosure is needed in this section to relate the factors to the specific circumstances of a fund and the investment advisory contract. Specifically, in the discussion of a fund's performance and expenses, the Staff suggests that we consider adding numerical comparisons of a fund's performance and expenses to an applicable peer group of similar funds.

R: We have submitted to the Staff a proposal that addresses the Staff's request to add fund-specific numerical performance and expense data to the disclosure. In light of the SEC's adoption in June 2004 of the final rule concerning the approval of investment advisory contracts, we are working on revised disclosure to comply with the rule and expect to have additional discussion with the Staff about this disclosure

35. All funds

"Proxy Voting Guidelines" (SAIs)

"The FMR Legal Department consults with the appropriate analysts or portfolio managers regarding the voting decisions of non-routine proposals that are not addressed by the Proxy Voting Guidelines.Each of the President or General Counsel of FMR or the General Counsel of FMR Corp is authorized to take a final decision."

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C: The Staff believes that the disclosure is sufficient to communicate how conflicts of interest are avoided, but requests that we add disclosure addressing how an identified conflict of interest would be handled.

R: In a future review of the Proxy Voting Guidelines with the Board of Trustees, we expect to propose adding disclosure as the Staff suggests.

36. All funds

Tandy (prospectuses and SAIs)

C: The Staff would like us to affirm the following three statements:

1) The fund is responsible for the adequacy and accuracy of the disclosure in the filings.

2) Staff comments or changes to disclosure in response to Staff comments in the filings reviewed by the Staff do not foreclose the Commission from taking any action with respect to the filing.

3) The fund may not assert Staff comments as a defense in any proceeding initiated by the Commission or any other person under the Federal Securities Laws.

R: We affirm the aforementioned statements.

Fidelity Advisor Emerging Asia Fund Class C (FERCX) CORRESPCorrespondence with SEC