Morgan Stanley Spectrum Select L.P.
C/O Demeter Management Corporation
522 Fifth Avenue, 13th Floor
New York, NY 10036
VIA EDGAR AND FEDERAL EXPRESS
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October 16, 2007
Division of Corporation Finance
Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Mail Stop 4561
Re: Morgan Stanley Spectrum Select L.P. (the "Company")
Form 10-K for Fiscal Year Ended December 31, 2006
Filed March 8, 2007
Form 10-Qs for Quarterly Periods Ended March 31, 2007 and June 30, 2007
Filed May 14, 2007 and August 10, 2007, respectively
File No. 000-19511
Ladies and Gentlemen:
In furtherance of the letter submitted by Cadwalader, Wickersham & Taft
LLP, on behalf of Demeter Management Corporation, the general partner of the
Company (the "General Partner"), dated October 9, 2007 in response to the
comment letter of the staff (the "Staff") of the Securities and Exchange
Commission (the "Commission") to Lee Horwitz, Chief Financial Officer of the
General Partner, dated September 12, 2007, with respect to the above-referenced
filings, the Company acknowledges that:
o the Company is responsible for the adequacy and accuracy of the disclosure
in the filings;
o Staff comments or changes to disclosure in response to Staff comments do
not foreclose the Commission from taking any action with respect to the
filings; and
o the Company 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.
Very truly yours,
Morgan Stanley Spectrum Select L.P.
By: Demeter Management Corporation, as General Partner of Morgan Stanley
Spectrum Select L.P.
By: /s/ Walter Davis
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Name: Walter Davis
Title: President
cc: Kevin Woody, Branch Chief
Jennifer Monick
Howard Efron
Lee Horwitz
Jeremy Beal
Michael D. Wasserman, Esq.
Todd M. Hand, Esq.
Edwin L. Lyon, Esq.