 March 9, 2016 | FOLEY & LARDNER LLP ATTORNEYS AT LAW 777 EAST WISCONSIN AVENUE MILWAUKEE, WISCONSIN 53202-5306 414.271.2400 TEL 414.297.4900 FAX www.foley.com WRITER’S DIRECT LINE 414.297.5596 pfetzer@foley.com Email CLIENT/MATTER NUMBER 012156-0101 |
Via Edgar
Securities and Exchange Commission 100 F Street, N.E. Washington, D.C. 20549 |
Re: The Primary Trend Fund, Inc. – Definitive Proxy Materials
Ladies and Gentlemen:
On behalf of The Primary Trend Fund, Inc., a Wisconsin corporation and an open-end management investment company registered under the Investment Company Act of 1940 (the “Fund”), we are transmitting for filing pursuant to Rule 14a-6 of the Securities Exchange Act of 1934, the Fund’s definitive notice of special meeting, proxy statement and form of proxy card (under the cover page required by Rule 14a-6(m) and Schedule 14A) for use in conjunction with the special meeting of shareholders. The special meeting has been set for March 31, 2016.
To the Fund’s knowledge, the only substantive matters to be considered at the special meeting of shareholders are to (i) elect three directors; (ii) approve a new investment advisory agreement between the Fund and Sims Capital Management LLC and (iii) approve a proposal to amend and restate the Fund’s Articles of Incorporation to change the name of the legal entity to “Sims Total Return Fund, Inc.” and authorize multiple classes of common stock.
If you have any questions or comments regarding this filing, please call Peter D. Fetzer at (414) 297-5596.
Very truly yours,
/s/ Peter. D. Fetzer
Peter D. Fetzer
/s/ Peter. D. Fetzer
Peter D. Fetzer
Attachments
| cc: | Lilli Gust Luke Sims |