LORD ABBETT SECURITIES TRUST
90 Hudson Street
Jersey City, NJ 07302
January 18, 2013
VIA EDGAR
U.S. Securities and Exchange Commission
Division of Investment Management
100 F Street, NE
Washington, DC 20549
Re: | Pre-Effective Amendment No. 3 to Registration Statement on |
Ladies and Gentlemen:
Pursuant to: (i) the Securities Act of 1933, as amended (the “1933 Act”); (ii) the General Instructions to Form N-14; and (iii) Regulation S-T, enclosed herewith for filing on behalf of the Company is Pre-Effective Amendment No. 3 (the “Amendment”) to the Company’s Registration Statement on Form N-14, which was filed with the Commission on November 29, 2012. The Amendment relates to the proposed reorganization of Lord Abbett Stock Appreciation Fund into Lord Abbett Growth Leaders Fund, a series of the Registrant.
The Amendment is being filed for the purpose of furnishing an undertaking to file the tax opinion required by Item 16(12) of Form N-14 upon the closing of the reorganization. The Company is concurrently filing a request for acceleration of the effectiveness of the Registration Statement, or as soon as practicable thereafter.
If you have any questions or comments, please do not hesitate to contact the undersigned at (201) 827-2225 or Brooke A. Fapohunda at (201) 827-2279.
Sincerely,
/s/ Thomas R. Phillips
Thomas R. Phillips
Vice President and Assistant Secretary