VIA EDGAR
Brent Fields, Assistant Director
Office of Disclosure and Review
Division of Investment Management
Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Re: | Fidelity Advisor Biotechnology Fund | Fidelity Government Income Fund |
| Fidelity Advisor Communications Equipment Fund | Fidelity Growth & Income Fund |
| Fidelity Advisor Consumer Discretionary Fund | Fidelity Intermediate Government Income Fund |
| Fidelity Advisor Electronics Fund | Fidelity International Real Estate Fund |
| Fidelity Advisor Energy Fund | Fidelity Leveraged Company Stock Fund |
| Fidelity Advisor Financial Services Fund | Fidelity Low Priced Stock Fund |
| Fidelity Advisor Health Care Fund | Fidelity OTC Portfolio |
| Fidelity Advisor Industrials Fund | Fidelity Real Estate Income Fund |
| Fidelity Advisor Leveraged Company Stock Fund | Fidelity Real Estate Investment Portfolio |
| Fidelity Advisor Real Estate Fund | Fidelity Series Commodity Strategy Fund |
| Fidelity Advisor Technology Fund | Fidelity Series Small Cap Opportunities Fund |
| Fidelity Advisor Utilities Fund | Fidelity Small Cap Growth Fund |
| Fidelity Blue Chip Growth Fund | Fidelity Small Cap Value Fund |
| Fidelity Blue Chip Value Fund | Fidelity Strategic Advisers Core Fund |
| Fidelity Commodity Strategy Fund | Fidelity Strategic Advisers Value Fund |
| Fidelity Dividend Growth Fund | Fidelity Ultra-Short Bond Fund |
| Fidelity GNMA Fund (formerly Fidelity Ginnie Mae Fund) | Fidelity Value Discovery Fund |
| Request pursuant to Rule 485(b)(1)(vii) | |
Dear Mr. Fields:
We are currently preparing the annual update filings for Fidelity Advisor Biotechnology Fund, Fidelity Advisor Communications Equipment Fund, Fidelity Advisor Consumer Discretionary Fund, Fidelity Advisor Electronics Fund, Fidelity Advisor Energy Fund, Fidelity Advisor Financial Services Fund, Fidelity Advisor Health Care Fund, Fidelity Advisor Industrials Fund, Fidelity Advisor Leveraged Company Stock Fund, Fidelity Advisor Real Estate Fund, Fidelity Advisor Technology Fund, Fidelity Advisor Utilities Fund, Fidelity Blue Chip Growth Fund, Fidelity Blue Chip Value Fund, Fidelity Commodity Strategy Fund, Fidelity Dividend Growth Fund, Fidelity GNMA Fund (formerly Fidelity Ginnie Mae Fund), Fidelity Government Income Fund, Fidelity Growth & Income Fund, Fidelity Intermediate Government Income Fund, Fidelity International Real Estate Fund, Fidelity Leveraged Company Stock Fund, Fidelity Low Priced Stock Fund, Fidelity OTC Portfolio, Fidelity Real Estate Income Fund, Fidelity Real Estate Investment Portfolio, Fidelity Series Commodity Strategy Fund, Fidelity Series Small Cap Opportunities Fund, Fidelity Small Cap Growth Fund, Fidelity Small Cap Value Fund, Fidelity Strategic Advisers Core Fund, Fidelity Strategic Advisers Value Fund, Fidelity Ultra-Short Bond Fund, and Fidelity Value Discovery Fund (the funds). Because the funds will include disclosure relating to the Enhanced Disclosure and New Prospectus Delivery Option for Registered Open-End Management Investment Companies Final Rule that is substantially the same as disclosure relating to the subject that was included in the 485(a) filings submitted to the Staff on October 16, 2009, November 16, 2009, December 15, 2009, January 15, 2010, and January 25, 2010 (see Attachment 1 for list of trusts/funds), we respectfully request permission to file the annual update filings for the funds under Rule 485(b)(1)(vii). The funds' filings contain other nonmaterial changes, including additional disclosure intended to highlight the disclosure included in the October 16, 2009, November 16, 2009, December 15, 2009, January 15, 2010, and January 25, 2010, 485(a) filings, but contain no other disclosures that would make them ineligible to file under Rule 485(b).
We would appreciate an early response to this request so that we can plan our filing schedule accordingly. Please call me at (617) 563-1375 if you have any questions or comments. Thank you for your consideration.
Identifying information for the funds for which this request is made is provided in Attachment 1.
Sincerely,
/s/ Jamie Plourde
Jamie Plourde
Senior Product Manager I
cc: Christian Sandoe
Attachment 1
Name of Trust and/or Fund(s) for which rule 485(b)(1)(vii) relief is requested: | Similar Trust/Fund(s) in which the new disclosure was previously subject to review: |
Fidelity Advisor Series I: 811-03785 | Fidelity Advisor Series I: |
Name of Trust and/or Fund(s) for which rule 485(b)(1)(vii) relief is requested: | Similar Trust/Fund(s) in which the new disclosure was previously subject to review: |
Fidelity Advisor Series VII: 811-03010 | Fidelity Advisor Series VIII: |
Name of Trust and/or Fund(s) for which rule 485(b)(1)(vii) relief is requested: | Similar Trust/Fund(s) in which the new disclosure was previously subject to review: |
Fidelity Commonwealth Trust II: 811-21990 | Fidelity Rutland Square Trust II: |
Name of Trust and/or Fund(s) for which rule 485(b)(1)(vii) relief is requested: | Similar Trust/Fund(s) in which the new disclosure was previously subject to review: |
Fidelity Devonshire Trust: 811-01352 | Fidelity Devonshire Trust: |
Name of Trust and/or Fund(s) for which rule 485(b)(1)(vii) relief is requested: | Similar Trust/Fund(s) in which the new disclosure was previously subject to review: |
Fidelity Fixed-Income Trust: 811-02105 | Fidelity Commonwealth Trust: ------------------------- Fidelity Investment Trust: |
Name of Trust and/or Fund(s) for which rule 485(b)(1)(vii) relief is requested: | Similar Trust/Fund(s) in which the new disclosure was previously subject to review: |
Fidelity Income Fund: 811-04085 | Fidelity School Street Trust: |
Name of Trust and/or Fund(s) for which rule 485(b)(1)(vii) relief is requested: | Similar Trust/Fund(s) in which the new disclosure was previously subject to review: |
Fidelity Puritan Trust: 811-00649 | Fidelity Capital Trust: |
Name of Trust and/or Fund(s) for which rule 485(b)(1)(vii) relief is requested: | Similar Trust/Fund(s) in which the new disclosure was previously subject to review: |
Fidelity Rutland Square Trust II: 811-21991 | Fidelity Rutland Square Trust II: |
Name of Trust and/or Fund(s) for which rule 485(b)(1)(vii) relief is requested: | Similar Trust/Fund(s) in which the new disclosure was previously subject to review: |
Fidelity Securities Fund: 811-04118 | Fidelity Mt. Vernon Street Trust: |