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JULIEN BOURGEOIS
julien.bourgeois@dechert.com
+1 202 261 3451 Direct
+1 202 261 3151 Fax
September 23, 2011
VIA EDGAR
Filing Desk
Securities and Exchange Commission
Office of Filings and Information Services
Branch of Registrations and Examinations
Mail Stop 0-25
100 F Street, NE
Washington, D.C. 20549
Re: Rydex Variable Trust (File No. 811-08821)
Rydex Series Funds (File No. 811-07584)
Rydex Dynamic Funds (File No. 811-09525)
(each a "Trust," and collectively, the "Trusts")
Ladies and Gentlemen:
Pursuant to Rule 14a-6 under the Securities Exchange Act of 1934, attached for
filing via the EDGAR system is a preliminary proxy statement, form of proxy, and
other soliciting material ("Proxy Materials") for a Joint Special Meeting of
Shareholders ("Meeting") of the Trusts to be held on November 22, 2011.
The Meeting is being held for the purpose of asking shareholders: (i) to approve
new Investment Advisory Agreements between Security Investors, LLC and the
Trusts, on behalf of each series of the Trusts in connection with a corporate
transaction that may result in a change in control; (ii) with respect to Rydex
Variable Trust-Amerigo Fund, Clermont Fund and Select Allocation Fund, to
approve a new Sub-Advisory Agreement between Security Investors, LLC and CLS
Investments, LLC; (iii) with respect to Rydex Variable Trust-DWA Flexible
Allocation Fund and DWA Sector Rotation Fund, to approve a new Sub-Advisory
Agreement between Security Investors, LLC and Dorsey, Wright & Associates, Inc.;
(iv) with respect to Rydex Series Funds-Long Short Interest Rate Strategy Fund,
to approve a new Sub-Advisory Agreement between Security Investors, LLC and
American Independence Financial Services, LLC; (v) to elect
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nominees to the Boards of Trustees of the Trusts; (vi) to approve a "manager of
managers" arrangement; and (vii) with respect to Rydex Variable Trust-U.S.
Government Money Market Fund and Rydex Series Funds-U.S. Government Money Market
Fund, to approve the elimination of the fundamental investment policy on
investing in other investment companies.
No fee is required in connection with this filing. Should you have any
questions or comments, please contact me at 202.261.3451.
Sincerely,
/s/ Julien Bourgeois
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Julien Bourgeois
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