LORD ABBETT SECURITIES TRUST
90 Hudson Street
Jersey City, NJ 07302
September 14, 2007
VIA EDGAR
Patricia Williams
Securities and Exchange Commission
Division of Investment Management
100 F Street, NE
Washington, DC 20549
Re: | Lord Abbett Securities Trust (the “Trust”) |
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| File Nos. 33-58846 and 811-07538 |
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Dear Ms. Williams:
This letter responds to comments you provided in an August 21, 2007 telephone conversation with Brooke A. Brown of Lord, Abbett & Co. LLC, the Trust’s investment adviser (“Lord Abbett”), regarding Post-Effective Amendment No. 53 to the Trust’s Registration Statement on Form N-1A (the “Registration Statement”). The comments, and the Trust’s responses thereto, are set forth below. Post-Effective Amendment No. 54 to the Registration Statement, which was filed today with the Securities and Exchange Commission and became effective immediately upon filing, reflects changes made in response to your comments.
Capitalized terms used but not defined herein have the meanings given to them in the Registration Statement.
Part A – Prospectus
1. Please revise the “Principal Strategy” and “Main Risks” sections of the prospectus to focus on the investment strategy of and risks associated with the Alpha Strategy Fund, rather than the investment strategies of and risks associated with the underlying funds in which it invests.
Response: We moved the list of the underlying funds and the tables regarding the Fund’s target allocations to Appendix A, which provides a summary of the key investment attributes of the underlying funds. We revised the disclosure in the “Principal Strategy” and “Main Risks” sections to place more emphasis on the Fund’s investment strategy and risks and less emphasis on the investment strategies and risks of the underlying funds.
2. Consolidate the line items captioned “Management Fee Waiver” and “Expense Reimbursement” in the Alpha Strategy Fund’s fee table.
Response: We have made the requested changes.
Part B – Statement of Additional Information
3. Please revise “Appendix A – Fund Portfolio Information Recipients” to identify actual recipients of the Funds’ portfolio holdings or related information, as opposed to third parties that may receive such holdings or information.
Response: We have revised the relevant disclosure to identify third parties that are eligible to receive portfolio holdings or related information pursuant to ongoing arrangements.
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If you have any questions, please call Brooke Brown at (201) 827-2279 or the undersigned at (201) 827-2264.
| Sincerely, | |
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| /s/ Christina T. Simmons |
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| Christina T. Simmons | |
| Vice President and Assistant Secretary | |
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