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December 21, 2017
VIA EDGAR
Securities and Exchange Commission
Judiciary Plaza
100 F Street, NE
Washington, D.C. 20549
Attn: James E. O’Connor, Division of Investment Management
| Re: | The Saratoga Advantage Trust |
Securities Act File No. 033-79708
Post-Effective Amendment No. 93
Investment Company Act File No. 811-08542
Amendment No. 95
Dear Mr. O’Connor:
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”), on behalf of James Alpha Multi Strategy Alternative Income Portfolio, a series of the Trust, hereby requests that the effectiveness for the above-referenced Registration Statement on Form N-1A be accelerated so that it will become effective as soon as practicable on December 29, 2017. 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,
/s/ Bruce E. Ventimiglia
Bruce E. Ventimiglia