SecProbe.io

CORRESP
1
main.htm

COMMENTS RECEIVED ON NOVEMBER 19, 2004, NOVEMBER 23, 2004, NOVEMBER 30, 2004,
and DECEMBER 6, 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

FIDELITY CAPITAL TRUST (File Nos. 002-61760 and 811-02841)

Fidelity Capital Appreciation Fund, Fidelity Disciplined Equity Fund, Fidelity Focused Stock Fund,
Fidelity Small Cap Independence Fund, Fidelity Stock Selector Fund, and Fidelity Value Fund

POST-EFFECTIVE AMENDMENT NO. 85

FIDELITY INVESTMENT TRUST (File Nos. 002-90649 and 811-04008)

 Fidelity Aggressive International Fund, Fidelity Canada Fund, Fidelity China Region Fund, Fidelity
Diversified International Fund, Fidelity Emerging Markets Fund, Fidelity Europe Capital Appreciation
Fund, Fidelity Europe Fund, Fidelity Global Balanced Fund, Fidelity International Discovery Fund, Fidelity
International Small Cap Fund, Fidelity Japan Fund, Fidelity Japan Smaller Companies Fund, Fidelity Latin
America Fund, Fidelity Nordic Fund, Fidelity Overseas Fund, Fidelity Pacific Basin Fund, Fidelity
Southeast Asia Fund, and Fidelity Worldwide Fund

POST-EFFECTIVE AMENDMENT NO. 89

NEWBURY STREET TRUST (File Nos. 002-78458 and 811-03518)

Treasury Fund, Prime Fund, and Tax-Exempt Fund

POST-EFFECTIVE AMENDMENT NO. 45

1.	All funds (except Treasury Fund, Prime Fund, and Tax-Exempt Fund)

"Buying and Selling Shares" (prospectuses)

"The fund's excessive trade monitoring policy described above does not apply to transactions initiated by
the trustee or adviser to a donor-advised charitable gift fund, qualified fund-of-funds or other strategy
funds, or omnibus accounts. Trustees or advisers of donor-advised charitable gift funds must certify that
they either work from an asset allocation model or direct transactions in the donor accounts in concert with
changes in a model portfolio and that donors are limited in their ability to influence investments by the
trust. A qualified fund-of-fund is a mutual fund or other strategy fund consisting of qualified plan assets
that either applies the fund's policies on frequent trading to shareholders at the top-fund level, or
demonstrates that it has policies designed to control frequent trading and that they are reasonably likely to
be effective as determined by the fund's Treasurer. The adviser to the top-fund level must also demonstrate
to the fund's Treasurer that its investment strategy will not lead to excessive trading. Strategy funds must
commence monitoring for excessive trading no later than March 31, 2005. Omnibus accounts are
maintained by intermediaries acting on behalf of multiple investors whose individual trades are not
ordinarily disclosed to the fund. Short-term trading by these investors is almost certain to go undetected by
the fund and may increase costs and disrupt portfolio management. The fund will monitor aggregate trading
in qualified fund-of-funds and known omnibus accounts to attempt to identify disruptive trades, focusing on
transactions in excess of $250,000. There is no assurance that these policies will be effective, or will
successfully detect or deter market timing."

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;
Fidelity Capital Trust (File Nos. 002-61760 and 811-02841), Post Effective Amendment No. 85; Fidelity
Investment Trust (File Nos. 002-90649 and 811-04008) Post Effective Amendment No. 89; Newbury Street
Trust (File Nos. 002-78458 and 811-03518), Post Effective Amendment No. 89

	C:	The Staff would like an explanation of how the funds will monitor aggregate trading in excess of
$250,000 and the steps taken if market timing is detected in a known omnibus account.

	R:	Our practice is to review trades in excess of $250,000 in an attempt to identify short-term
trading that may be disruptive to portfolio management. If detected, we will contact the omnibus
account holders and ask them to explain who the underlying investors are, and what their
intentions are. We urge omnibus account holders to impede potentially disruptive trading
activity at their level. If the omnibus account holder's explanation fails to reassure FMR that the
account holder's subsequent trading is not likely to be disruptive, FMR may prevent further
exchanges by electronic means, requiring mailing of exchange transactions.

2.	Treasury Fund, Prime Fund, and Tax-Exempt Fund

"Buying and Selling Shares" (prospectuses)

"Frequent purchases and sales of fund shares can harm shareholders in various ways, including reducing the
returns to long-term shareholders by increasing costs to the fund (such as spreads paid to dealers who sell
money market instruments to the fund) and disrupting portfolio management strategies. Accordingly, the
Board of Trustees has adopted policies and procedures designed to discourage excessive or short-term trading
of fund shares. As money market funds, each fund is designed to offer investors a liquid cash option and
FMR anticipates that shareholders will purchase and sell fund shares frequently.

Each fund has no limit on purchase or exchange transactions. Accordingly, the Board of Trustees has not
adopted policies and procedures designed to discourage excessive or short-term trading of fund shares and
each fund accommodates frequent trading. Each fund reserves the right, but does not have the obligation, to
reject any purchase or exchange transaction at any time. In addition, FMR reserves the right to impose
restrictions on purchases or exchanges at any time on conditions that are more restrictive on disruptive,
excessive, or short-term trading than those that are otherwise stated in this prospectus."

	C:	The Staff believes that the two underlined sentences above are inconsistent.

	R:	We will modify the disclosure in the next filing as follows (underlined added; [bracketed]
deleted):

"Frequent purchases and sales of fund shares can harm shareholders in various ways, including reducing the
returns to long-term shareholders by increasing costs to the fund (such as spreads paid to dealers who sell
money market instruments to a fund) and disrupting portfolio management strategies. However, FMR
anticipates that shareholders will purchase and sell fund shares frequently because each fund is designed to
offer investors a liquid cash option. Accordingly, the Board of Trustees has not adopted policies and
procedures designed to discourage excessive or short-term trading of fund shares and each fund
accommodates frequent trading. [As money market funds, each fund is designed to offer investors a liquid
cash option and FMR anticipates that shareholders will purchase and sell fund shares frequently.]

Each fund has no limit on purchase or exchange transactions. [Accordingly, the Board of Trustees has not
adopted policies and procedures designed to discourage excessive or short-term trading of fund shares and
each fund accommodates frequent trading.] Each fund reserves the right, but does not have the obligation, to
reject any purchase or exchange transaction at any time. In addition, FMR reserves the right to impose
restrictions on purchases or exchanges at any time on conditions that are more restrictive on disruptive,
excessive, or short-term trading than those that are otherwise stated in this prospectus.''

3.	All funds (except Treasury Fund, Prime Fund, and Tax-Exempt Fund)

"Buying and Selling Shares" (prospectuses)

"The fund's Treasurer is authorized to suspend the fund's policies during periods of severe market
turbulence or national emergency and to grant exemptions from the policy."

	C:	The Staff requests specifics on when the policies will not be imposed and whether there are
specific people that the fund accommodates market timing for pursuant to Item 6(e)(4)(iii) of
Form N-1A. In addition the Staff requests that the fund state in its disclosure whether or not it
accommodates market timing pursuant to Item 6(e)(4)(ii) of Form N-1A.

	R:	The fund will not accept more than two 30 day roundtrips within any 90 day period, except as
otherwise provided for the specified account types: omnibus, fund-of-fund, and qualified wrap
programs. We will add the following disclosure:

		"The fund does not knowingly accommodate purchases and redemptions of fund shares in
excess of the polices set out in this prospectus."

4.	All funds (except Treasury Fund, Prime Fund, and Tax-Exempt Fund)

"Buying and Selling Shares" (prospectuses)

"Qualified wrap programs will be monitored by matching the adviser's orders for purchase, exchange, or
sale transactions in fund shares to determine if the adviser's orders comply with the fund's frequent trading
policies. Excessive trading by an adviser will lead to fund blocks and the wrap program will cease to be a
qualified wrap program. [Additions to and withdrawals from a qualified wrap program by the adviser's
client will not be matched with transactions initiated by the adviser, but client initiated transactions are
subject to the fund's policies on frequent trading and individual clients may be subject to restrictions due to
their frequent trading in a wrap account.] Commencing no later than March 31, 2005, wrap account client
purchases and sale transactions will be monitored under the fund's monitoring policy as though the wrap
clients were fund shareholders. A qualified wrap program is: i) a program whose adviser certifies that it has
investment discretion over $100 million or more in client assets invested in mutual funds at the time of the
certification, ii) a program in which the adviser directs transactions in the accounts participating in the
program in concert with changes in a model portfolio, and iii) managed by an adviser who agrees to give
FMR sufficient information to permit FMR to identify the individual accounts in the wrap program."

	C:	The Staff asks: a) Is it "may" or "will" be subject to restrictions?; b) What are the restrictions?
and; c) What does the first clause of the underlined text mean?

	R:	 a) We will modify the disclosure to change "may" to "will"; b) A client who buys and then sells
shares of a fund within 30 days two or more times within any 90 day period will be blocked
from making additional purchases or exchanges of the fund for 85 days, and; c) A roundtrip
transaction occurs when a shareholder buys and then sells shares of a fund within 30 days.
However, if the adviser buys shares of a fund and an individual client subsequently sells shares
of the same fund within 30 days, the client's transaction is not matched with the adviser's and
therefore does not count as a roundtrip.

5.	Fidelity Advisor Diversified International Fund, Fidelity Advisor Europe Capital Appreciation Fund,
Fidelity Advisor Global Equity Fund, Fidelity Advisor International Capital Appreciation Fund, Fidelity
Advisor Overseas Fund, Fidelity Aggressive International Fund, Fidelity Diversified International Fund,
Fidelity Europe Capital Appreciation Fund, Fidelity Europe Fund, Fidelity Focused Stock Fund, Fidelity
Global Balanced Fund, Fidelity International Discovery Fund, Fidelity Overseas Fund, and Fidelity
Worldwide Fund

"Buying and Selling Shares" (prospectuses)

"Selling Shares"

(Fidelity Advisor Diversified International Fund, Fidelity Advisor Europe Capital Appreciation Fund,
Fidelity Advisor Global Equity Fund, Fidelity Advisor International Capital Appreciation Fund, and
Fidelity Advisor Overseas Fund)

"The fund will deduct a 1.00% short-term trading fee from the redemption amount if you sell your shares or
your shares are redeemed for failure to maintain the account minimum after holding them less than 30 days.
For this purpose, shares held longest will be treated as being redeemed first and shares held shortest as
being redeemed last. The short-term trading fee does not apply to shares that were acquired through
reinvestment of distributions."

(Fidelity Europe Fund and Fidelity Europe Capital Appreciation Fund)

"Canada, China Region, Emerging Markets, Japan, Japan Smaller Companies, Latin America, Nordic, Pacific
Basin, and Southeast Asia will deduct a 1.50% short-term trading fee from the redemption amount if you sell
your shares or your shares are redeemed for failure to maintain the balance minimum after holding them less
than 90 days. Europe and Europe Capital Appreciation will deduct a 1.00% short-term trading fee from the
redemption amount if you sell your shares or your shares are redeemed for failure to maintain the balance
minimum after holding them less than 30 days. For this purpose, shares held longest will be treated as being
redeemed first and shares held shortest as being redeemed last. The short-term trading fee does not apply to
shares that were acquired through reinvestment of distributions. If you sell shares through a retirement account
you may or may not pay a short-term trading fee."

(Fidelity Aggressive International Fund, Fidelity Diversified International Fund, Fidelity Global Balanced
Fund, Fidelity Overseas Fund, and Fidelity Worldwide Fund)

"Each fund will deduct a 1.00% short-term trading fee from the redemption amount if you sell your shares or
your shares are redeemed for failure to maintain the balance minimum after holding them less than 30 days. For
this purpose, shares held longest will be treated as being redeemed first and shares held shortest as being
redeemed last. The short-term trading fee does not apply to shares that were acquired through reinvestment of
distributions. If you sell shares through a retirement account you may or may not pay a short-term trading fee."

(Fidelity International Discovery Fund)

"The fund will deduct a 1.00% short-term trading fee from the redemption amount if you sell your shares or
your shares are redeemed for failure to maintain the balance minimum after holding them less than 30 days.
For this purpose, shares held longest will be treated as being redeemed first and shares held shortest as
being redeemed last. The short-term trading fee does not apply to shares that were acquired through
reinvestment of distributions. If you sell shares through a retirement account you may or may not pay a
short-term trading fee."

(Fidelity Focused Stock Fund)

"Focused Stock will deduct a 0.75% short-term trading fee from the redemption amount if you sell your
shares or your shares are redeemed for failure to maintain the balance minimum after holding them less
than 30 days. For this purpose, shares held longest will be treated as being redeemed first and shares held
shortest as being redeemed last. The short-term trading fee does not apply to shares that were acquired
through reinvestment of distributions. If you s