The Saratoga Advantage Trust
1101 Stewart Avenue, Suite 207
Garden City, New York 11530
January 28, 2011
Securities and Exchange Commission
Judiciary Plaza
100 F Street, NE
Washington, D.C. 20549
Attention:
Dominic Minore, Division of Investment Management
Re:
The Saratoga Advantage Trust
Securities Act File No. 033-79708
Investment Company Act File No. 811-08542
Post-Effective Amendment No. 35
Dear Mr. Minore:
In accordance with Rule 461 of the General Rules and Regulations under the Securities Act of 1933, as amended (the “Securities Act”), The Saratoga Advantage Trust (the “Trust”) hereby requests that the effectiveness for Post-Effective Amendment Number 35 to the above-referenced Registration Statement on Form N-1A be accelerated to 5:00 p.m., New York time, on January 31, 2011, or as soon thereafter as practicable. The Trust hereby confirms that it is aware of its obligations under the Securities Act and the Securities Exchange Act of 1934, as amended.
Very truly yours,
By:
/s/ BRUCE E. VENTIMIGLIA
Bruce E. Ventimiglia
President, CEO and
Chairman of the Board of Trustees