Morgan Stanley Information Fund 1221 Avenue of the Americas New York, NY 10020 August 1, 2005 Securities and Exchange Commission 100 F Street, N.E. Washington, D.C. 20549 Attention: Larry Greene, Division of Investment Management Mail Stop 0505 RE: MORGAN STANLEY INFORMATION FUND (FILE NO. 33-87472) Dear Mr. Greene: Thank you for your additional telephonic comment of July 28, 2005 regarding the registration statement on Form N-1A for Morgan Stanley Information Fund (the "Fund") filed with the Securities and Exchange Commission on May 26, 2005. Below, we provide our response to the Staff's comment, as requested. COMMENT 1. PLEASE SUPPLEMENTALLY EXPLAIN HOW THE FOLLOWING STATEMENT INCLUDED ON PAGE 1 OF THE PROSPECTUS IS CONSISTENT WITH THE 50% TEST THAT IS APPLIED TO INVESTMENT COMPANIES THAT INVEST IN A SPECIFIC COUNTRY OR REGION: "A COMPANY IS CONSIDERED TO BE IN THE COMMUNICATIONS AND INFORMATION INDUSTRY IF IT DERIVES AT LEAST 35% OF ITS REVENUES OR EARNINGS FROM, OR DEVOTES AT LEAST 35% OF ITS ASSETS TO DESIGNING, DEVELOPING, MANUFACTURING, PROVIDING OR ENABLING THE FOLLOWING PRODUCTS AND SERVICES: REGULAR TELEPHONE SERVICE; COMMUNICATIONS EQUIPMENT AND SERVICES;..." Response 1. Release No. IC-24828 states that "if an ----------- investment company uses a criterion that requires qualifying investments to be in issuers that derive a specified proportion of their revenues or profits from goods produced or sold, investments made, or services performed in the applicable country or region, or that have a specified proportion of their assets in that country or region, the [Securities and Exchange Commission], consistent with its current position, would expect the proportion used to be at least 50%, in order for the investments to be deemed to be tied economically to the country or region." This restriction is applied to investment companies that have names that indicate an investment emphasis in certain countries or geographical regions and is not applied to investment companies that have names that indicate an investment emphasis in certain investments or industries. Therefore, we respectfully acknowledge your comment, but believe that the disclosure as stated and applied to the Fund is sufficient. As you have requested and consistent with SEC Press Release 2004-89, the Fund hereby acknowledges that: o the Fund is responsible for the adequacy and accuracy of the disclosure in the filings; o the Staff's comments or changes to disclosure in response to Staff comments in the filings reviewed by the Staff do not foreclose the Commission from taking any action with respect to the filings; and o the Fund may not assert Staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. If you would like to discuss this response in further detail or if you have any questions, please feel free to contact me at (630) 684-6301. Thank you. Sincerely, /s/ Elizabeth Nelson - -------------------- Elizabeth Nelson
- Company Dashboard
- Filings
-
CORRESP Filing
Morgan Stanley Technology Fund Inactive CORRESPCorrespondence with SEC
Filed: 1 Aug 05, 12:00am