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COMMENTS RECEIVED ON NOVEMBER 23, 2004

FROM CHRISTIAN SANDOE

FIDELITY ADVISOR SERIES II (File Nos. 033-06516 and 811-04707)

 Fidelity Advisor Floating Rate High Income Fund, Fidelity Advisor Government
Investment Fund, Fidelity Advisor High Income Fund, Fidelity Advisor High Income
Advantage Fund, Fidelity Advisor Intermediate Bond Fund, Fidelity Advisor Mortgage
Securities Fund, Fidelity Advisor Municipal Income Fund, Fidelity Advisor Short
Fixed-Income Fund, and Fidelity Advisor Value Fund

POST-EFFECTIVE AMENDMENT NOS. 70 & 72

FIDELITY ADVISOR SERIES VIII (File Nos. 002-86711 and 811-03855)

 Fidelity Advisor Diversified International Fund, Fidelity Advisor Emerging Asia Fund,
Fidelity Advisor Emerging Markets Fund, Fidelity Advisor Europe Capital Appreciation
Fund, Fidelity Advisor Global Equity Fund, Fidelity Advisor International Capital
Appreciation Fund, Fidelity Advisor Japan Fund, Fidelity Advisor Korea Fund, Fidelity
Advisor Latin America Fund, Fidelity Advisor Overseas Fund, and Fidelity Advisor
Value Leaders Fund

POST-EFFECTIVE AMENDMENT NO. 77

FIDELITY BEACON STREET TRUST (File Nos. 002-64791 and 811-02933)

 Fidelity Advisor Tax Managed Stock Fund and Fidelity Tax Managed Stock Fund

POST-EFFECTIVE AMENDMENT NO. 56

1.	All funds (as applicable)

	Performance Charts, Fee Tables, Financial Highlights, and Trustee Compensation Tables (prospectuses and
statements of additional information (SAIs))

	C:	Please submit completed performance charts, fee tables, financial highlights,
and the trustee compensation tables when the information becomes available.

	R:	The requested information will be faxed to you when it becomes available.

2.	Fidelity Advisor Value Leaders Fund

"Front Cover" (prospectuses)

	C:	Is the name of the fund one or two concepts, is it meant to be "value and
leaders" or "value leaders"? What does it mean?

	R:	The terms "value" and "leaders" in the fund's name represent one concept,
value companies that are large and well-known. This concept corresponds to the
fund's principal investment strategies of "investing primarily in common stocks
of well-known and established companies" and "investing in securities of
companies that it believes are undervalued in the marketplace."

Fidelity Advisor Series II (File Nos. 033-06516 and 811-04707), Post-Effective Amendment Nos. 70 & 72;
Fidelity Advisor Series VIII (File Nos. 002-86711 and 811-03855), Post-Effective Amendment No. 77;
Fidelity Beacon Street Trust (File Nos. 002-64791 and 811-02933), Post-Effective Amendment No. 56

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3.	Fidelity Advisor Value Leaders Fund

"Investment Summary" (prospectuses)

"Principal Investment Strategies"

"Normally investing at least 80% of assets in blue chip companies (companies whose stock is included in
the Standard & Poor's 500 Index (S&P 500) or the Dow Jones Industrial Average (DJIA), and companies
with market capitalizations of at least $1 billion if not included in either index)."

	C:	There appears to be two criteria for the fund's 80% name test, a set of indices
and companies with market capitalizations of at least $1 billion. The second
criteria doesn't seem to be anything that would get the fund near blue chip or
seen as a leader. How does this fit with the fund's name?

	R:	We note that the fund does not have a name test policy, as neither term in its
name triggers application of the Name Test Rule. The fund does, however, have
a policy of investing at least 80% of assets in blue chip companies, based upon
FMR's definition of "blue chip." The fund also has a principal investment
strategy of "[n]ormally investing primarily in common stocks of well-known
and established companies." While the S&P 500 and DJIA are commonly
regarded as indices of stocks of companies that are "well-known and
established," the fund could invest in stocks of similar quality not included in
either index. We believe that identifying a market capitalization range of at least
$1 billion, when considered in connection with the fund's principal investment
strategy of investing primarily in the common stocks of well-known and
established companies, provides a reasonable approach for identification of
"blue chip companies."

4.	Fidelity Advisor High Income Advantage Fund, Fidelity Advisor High Income Fund, Fidelity Advisor
Global Equity Fund, Fidelity Advisor Diversified International Fund, Fidelity Advisor Latin America Fund,
Fidelity Advisor Korea Fund, Fidelity Advisor Overseas Fund, and Fidelity Advisor Europe Capital
Appreciation Fund

"Investment Summary" (prospectuses)

"Principal Investment Risks"

(Fidelity Advisor High Income Advantage Fund, Fidelity Advisor High Income Fund, Fidelity Advisor
Global Equity Fund, and Fidelity Advisor Diversified International Fund)

"Foreign Exposure. Foreign markets, particularly emerging markets, can be more volatile than the U.S.
market due to increased risks of adverse issuer, political, regulatory, market, or economic developments and
can perform differently from the U.S. market."

(Fidelity Advisor Latin America Fund, Fidelity Advisor Korea Fund, Fidelity Advisor Overseas Fund, and
Fidelity Advisor Europe Capital Appreciation Fund)

"Foreign Exposure. Foreign markets, particularly emerging markets, can be more volatile than the U.S.
market due to increased risks of adverse issuer, political, regulatory, market, or economic developments and
can perform differently from the U.S. market. Emerging markets can be subject to greater social, economic,
regulatory, and political uncertainties and can be extremely volatile."

	C:	The Staff would like emerging markets added as a strategy under the "Principal
Investment Strategies" heading.

	R:	Though the non-U.S. securities in which the funds invest may include foreign
issuers in both developed and emerging markets, these funds currently do not
have a principal investment strategy of investing in emerging markets.

Fidelity Advisor Series II (File Nos. 033-06516 and 811-04707), Post-Effective Amendment Nos. 70 & 72;
Fidelity Advisor Series VIII (File Nos. 002-86711 and 811-03855), Post-Effective Amendment No. 77;
Fidelity Beacon Street Trust (File Nos. 002-64791 and 811-02933), Post-Effective Amendment No. 56

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5.	Fidelity Advisor Value Fund, Fidelity Advisor Diversified International Fund, Fidelity Advisor Emerging
Asia Fund, Fidelity Advisor Emerging Markets Fund, Fidelity Advisor Europe Capital Appreciation Fund,
Fidelity Advisor Global Equity Fund, Fidelity Advisor International Capital Appreciation Fund, Fidelity
Advisor Japan Fund, Fidelity Advisor Korea Fund, Fidelity Advisor Latin America Fund, Fidelity Advisor
Overseas Fund, Fidelity Tax Managed Stock Fund, and Fidelity Advisor Tax Managed Stock Fund

"Investment Summary" (prospectuses)

"Principal Investment Strategies"

	C:	What is the fund's market capitalization strategy?

	R:	The funds do not have a principal investment strategy of investing in securities
of companies with a particular market capitalization.

6.	Fidelity Advisor Global Equity Fund

"Investment Summary" (prospectuses)

"Principal Investment Strategies"

"Allocating investments across countries and regions considering the size of the market in each country and
region relative to the size of the world market as a whole."

	C:	The Staff noted that the Name Test Rule makes reference to what would be
expected of a global fund. The Staff suggests changing the above disclosure to
say "Allocating investments across several countries and regions . . ."

	R:	We would be happy to discuss the Staff's comment further, but are hesitant to
make this change, as it could be misleading. The term "several" is commonly
understood to mean three or four, and the fund invests in a far greater number of
countries and regions. For example, as of April 30, 2004, the fund was investing
in approximately 25 countries and regions.

7.	Fidelity Advisor Floating Rate High Income Fund

"Investment Summary" (prospectuses)

"Principal Investment Risks"

"Impairment of Collateral. A floating rate loan may not be fully collateralized which may cause the
floating rate loan to decline significantly in value."

	C:	If a floating rate loan may not be fully collateralized, how can the collateral be
impaired?

	R:	Collateral impairment is the risk that the value of the collateral for a floating
rate loan will be insufficient in the event that a borrower defaults. Although the
terms of a floating rate loan generally require that the collateral at issuance have
a value at least equal to 100% of the amount of such loan, the value of the
collateral may decline subsequent to the purchase of the loan, causing the loan
to be undercollaterlized and to decrease in value.

8.	Fidelity Advisor Floating Rate High Income Fund, Fidelity Advisor High Income Fund, and Fidelity
Advisor High Income Advantage Fund

"Investment Summary" (prospectuses)

"Principal Investment Strategies"

	C:	The Staff believes that a discussion of the fund's maturity policy should be
included in this section.

	R:	The funds do not have a principal investment strategy to invest in securities of a
particular maturity.

9.	Fidelity Advisor High Income Advantage Fund

"Investment Summary" (prospectuses)

"Principal Investment Risks"

	C:	The Staff notes that although the placement of the "stock market volatility" risk
disclosure is consistent with other Fidelity funds' prospectuses, it seems odd
that it would be the first and seemingly most important risk in the context of this
fund, which can invest up to 20% in common stocks.

	R:	Item 2(c)(1)(i) of Form N-1A does not require or suggest that we should specify
the principal risks of investing in the fund in any particular order of perceived
importance. As market conditions change during the life of a prospectus, certain
risks may become more prominent than others, and therefore become more
likely to affect adversely the fund's net asset value, yield, or total return. We are
concerned that ranking risks as of the effective date of a prospectus may not be
a meaningful ranking for the life of the prospectus and therefore have not
modified our disclosure.

10.	Fidelity Advisor Intermediate Bond Fund and Fidelity Advisor Short Fixed-Income Fund

"Investment Summary" (prospectuses)

"Principal Investment Strategies"

"Normally investing at least 80% of assets in investment-grade debt securities (those of medium and high
quality) of all types and repurchase agreements for those securities."

	C:	The Staff believes that the fund should invest 80% in bonds, which can then be
defined as debt securities or investment-grade debt securities, as applicable.

	R:	We believe that any requirement under Rule 35d-1 of the 1940 Act for the fund
to have a policy to invest 80% in bonds is met by its policy to invest 80% in
debt securities. In this regard, as previously discussed with the Staff, we
continue to take the position we have taken historically, which is that the term
"bond" suggests debt securities of all types (see Stan Griffith's June 21, 1990
letter to David Wills, then Branch Chief of the SEC's Division of Investment
Management). We note that the Commission, when adopting Rule 35d-1, did
not elaborate on the types of debt securities suggested by the term "bond."
Moreover, we believe that complying with the Staff's request that the fund
adopt a policy of investing in "bonds" and then defining bonds to be the types
of securities currently referenced in the fund's 80% policy differs from the
current disclosure in form only, not in substance, and reflects an
acknowledgment that the substance of the fund's 80% policy is acceptable.
Accordingly, we believe that the fund's name and 80% policy are consistent
with Rule 35d-1 and have not revised the disclosure as suggested.

Fidelity Advisor Series II (File Nos. 033-06516 and 811-04707), Post-Effective Amendment Nos. 70 & 72;
Fidelity Advisor Series VIII (File Nos. 002-86711 and 811-03855), Post-Effective Amendment No. 77;
Fidelity Beacon Street Trust (File Nos. 002-64791 and 811-02933), Post-Effective Amendment No. 56

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11.	Fidelity Advisor Intermediate Bond Fund and Fidelity Advisor Short Fixed-Income Fund

"Investment Summary" (prospectuses)

"Principal Investment Risks"

"Foreign Exposure. Entities located in foreign countries can be affected by adverse political, regulatory,
market, or economic developments in those countries."

	C:	The Staff believes that the above risk disclosure found under the sub-heading
"Principal Investment Risks" in the "Investment Summary" section should have
a corresponding strategy identified under the sub-heading "Principal Investment
Strategies" in the "Investment Summary" section.

	R:	Each fund has a principal investment strategy of investing in investment-grade
debt securities of all types. These debt securities can include debt issued by
foreign issuers or by U.S. entities with substantial foreign operations, and debt
for which a foreign entity has provided credit support. The fund's investment in
these particular types of debt securities does not rise to the level of a "Principal
Investment Strategy," but these types of debt securities may nonetheless present
a "Principal Investment Risk" of foreign exposure which we believe should be
disclosed. Accordingly, we have not added the disclosure as the Staff has
suggested.

12.	Fidelity Advisor Mortgage Securities Fund

"Investment Summary" (prospectuses)

"Principal Investment Strategies"

"Normally investing at least 80% of assets in investment-grade mortgage-related securities (those of
medium and high quality) and repurchase agreements for those securities."

	C:	What does the term mortgage-related securities mean? Does it mean securities
with economic characteristics similar to the name?

	R:	The term "mortgage-related securities" is summarized in the "Investment
Details" section of the prospectus under the heading "Mortgage Securities" in
the "Description of Principal Security Types" section, as well as in the SAI
under the same heading within the "Investment Policies and Limitations"
section.

13.	Fidelity Advisor Floating Rate High Income Fund, Fidelity Advisor Government Investment Fund, Fidelity
Advisor High Income Fund, Fidelity Advisor High Income Advantage Fund, Fidelity Advisor Intermediate
Bond Fund, Fidelity Advisor Mortgage Securities Fund, Fidelity Advisor Municipal Income Fund, and
Fidelity Advisor Short Fixed-Income Fund

"Investment Summary" (prospectuses)

"Principal Investment Risks"

	C:	The Staff believes that corresponding credit risk disclosure should be added
under the sub-heading "Principal Investment Risks" in the "Investment
Summary" section to reflect the risks involved in investing in debt securities.

	R:	We direct the Staff's attention to the disclosure concerning "Issuer-Specific
Changes" under the heading "Principal Investment Risks" in the "Investment
Summary" section. This disclosure summarizes the risks associated with
changes in an issuer's credit quality by recognizing that, for reasons specific to
a particular issuer, "[t]he value of an individual security or particular type of
security can be more volatile than the market as a whole and can perform
differently from the value of the market as a whole." For Fidelity Advisor
Floating Rate High Income Fund, Fidelity Advisor High Income Fund, and
Fidelity Advisor High Income Advantage Fund the disclosure also summarizes
the credit risk associated with investments in lower quality debt securities.
Many issuer-specific risk factors can impact an issuer's credit quality and cause
the value or credit quality of its securities to decline when the market as a whole
may be rising, including changes in the financial condition of a particular iss