Morgan, Lewis & Bockius LLP
1111 Pennsylvania Avenue, NW [GRAPHIC OMITTED]
Washington, DC 20004
Tel. 202.739.3000
Fax: 202.739.3001
www.morganlewis.com
July 27, 2005
VIA EDGAR
U.S. Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Re: RYDEX SERIES FUNDS (FILE NOS. 033-59692 AND 811-07584), RYDEX DYNAMIC
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FUNDS (FILE NOS. FILE NO. 333-84797 AND 811-09525), RYDEX VARIABLE
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TRUST (FILE NOS. 333-57017 AND 811-08821), AND RYDEX ETF TRUST (FILE
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NOS. 333-101625 AND 811-21261)
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Ladies and Gentlemen:
On behalf of Rydex Series Funds, Rydex Dynamic Funds, Rydex Variable Trust, and
Rydex ETF Trust (each a "Trust" and together, the "Trusts"), we are filing,
pursuant to the Securities Exchange Act of 1934 and the Investment Company Act
of 1940, a preliminary Schedule 14A, notice, proxy statement and form of voting
instruction form for a Special Meeting of Shareholders ("Meeting") of the Trusts
scheduled to be held on or about October 4, 2007.
The Meeting is being called for the purposes of approving new advisory
agreements between PADCO Advisors, Inc. and Rydex Series Funds and Rydex Dynamic
Funds, and PADCO Advisors II, Inc. and Rydex Variable Trust and Rydex ETF
Trusts, as well as a new sub-advisory agreement between PADCO Advisors II, Inc.
and CLS Investment Firm, LLC. It is anticipated that the current investment
advisory and sub-advisory agreements will terminate if and when a change of
control occurs in Rydex Holdings, Inc., the parent company of PADCO Advisors,
Inc. and PADCO Advisors II, Inc., resulting from the transfer of ownership of
Rydex Holdings, Inc. to Security Benefit Corporation and Security Benefit Life
Insurance Company.
The Trusts intend to mail definitive proxy materials to shareholders on or about
September 3, 2007. Please feel free to contact me at 202.739.5684 with your
questions or comments.
Sincerely,
/s/ Laura E. Flores
Laura E. Flores