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COMMENTS RECEIVED ON 03/16/2022

FROM DANIEL GREENSPAN

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

Fidelity SAI Sustainable Emerging Markets Equity Fund, Fidelity SAI Sustainable International Equity Fund

POST-EFFECTIVE AMENDMENT NO. 193

FIDELITY SUMMER STREET TRUST (File Nos. 002-58542 and 811-02737)

Fidelity SAI Sustainable Future Fund, Fidelity SAI Sustainable Sector Fund, Fidelity SAI Sustainable U.S. Equity Fund

POST-EFFECTIVE AMENDMENT NO. 199

1)

C:    The Staff requests we respond to these comments no later than five business days before the filing is scheduled to become effective automatically. If this isn’t possible, the Staff requests we file to delay an amendment under 485(b).

R:

We will make reasonable efforts to respond to comments within the requested timeframe.

2)

C:    The Staff requests we fill in all blanks, brackets, and otherwise missing information sufficiently in advance of effectiveness for review.

R:

We will make reasonable efforts to provide the requested information that the registrant believes is material for review purposes sufficiently in advance of effectiveness.

3)

“Fund Summary” (prospectus)

“Fee Table”

C:

The Staff requests we provide the fees and expenses sufficiently in advance of effectiveness for review.

R:

Please see the attached completed information.

4)

“Fund Summary” (prospectus)

“Fee Table”

C:

The Staff requests we provide the example sufficiently in advance of effectiveness for review.

R:

Please see the attached completed information.

5)

All funds

“Cover”

“Offered exclusively to certain clients of the Adviser or its affiliates — not available for sale to the general public. Fidelity SAI is a product name of Fidelity® funds dedicated to certain programs affiliated with Strategic Advisers LLC.”

C:

The Staff requests we explain here who Strategic Advisers LLC is and its relationship to the registrant.

R:

We will modify the disclosure on the front cover to make clear that Strategic Advisers LLC is an affiliate of the Adviser, as follows:

“Offered exclusively to certain clients of the Adviser, or its affiliates, including Strategic Advisers LLC (SAI) — not available for sale to the general public. Fidelity SAI is a product name of Fidelity® funds dedicated to certain programs affiliated with Strategic Advisers LLC SAI.”

6)

All funds

“Fund Summary” (prospectus)

“Principal Investment Strategies”

Example from SAI Sustainable Future Fund:

“Normally investing at least 80% of assets in securities of issuers that Fidelity Management & Research Company LLC (FMR) (the Adviser) believes have proven or improving sustainability practices based on an evaluation of such issuers’ individual environmental, social, and governance (ESG) profile. In general, the Adviser favors those issuers it believes are well positioned to continue to improve their ESG profile in the future.”

C:

The Staff requests we define “sustainability” and its relationship to ESG.

R:

We believe our disclosure defines sustainability and its relationship to ESG. We therefore decline to modify the disclosure.

7)

All funds

“Fund Summary” (prospectus)

“Principal Investment Strategies”

Example from SAI Sustainable Future Fund:

“Normally investing at least 80% of assets in securities of issuers that Fidelity Management & Research Company LLC (FMR) (the Adviser) believes have proven or improving sustainability practices based on an evaluation of such issuers’ individual environmental, social, and governance (ESG) profile. In general, the Adviser favors those issuers it believes are well positioned to continue to improve their ESG profile in the future.”

C:

The Staff requests we explain what is meant by “proven” and what the criteria are to determine if an issuer has “proven or improving sustainability practices.”

R:

We believe the disclosure under “Principal Investment Strategies” in the “Fund Summary” section clearly discloses the criteria FMR uses to determine whether an issuer has “proven or improving sustainability practices.” FMR’s proprietary ESG ratings process is used to evaluate the current state of a company’s sustainability practices using a data-driven framework that includes both proprietary and third-party data, and also provide a qualitative forward looking assessment of a company’s sustainability outlook provided by FMR’s fundamental research analysts and ESG team. In addition, FMR’s ESG ratings are derived from multiple factors which are weighted based on how material FMR believes each factor is to a company’s financial outlook, and not all factors may be applicable to all companies. We believe that FMR’s ESG ratings process appropriately defines the criteria used to determine if an issuer has “proven or improving sustainability practices.”

8)

Fidelity SAI Sustainable Future Fund

“Fund Summary” (prospectus)

“Principal Investment Strategies”

“Normally investing at least 80% of assets in securities of issuers that Fidelity Management & Research Company LLC (FMR) (the Adviser) believes have proven or improving sustainability practices based on an evaluation of such issuers’ individual environmental, social, and governance (ESG) profile. In general, the Adviser favors those issuers it believes are well positioned to continue to improve their ESG profile in the future.”

C:

The Staff request we clarify what the underlined language above means. For example, could ESG practices be poor but improving?

R:

Pursuant to FMR’s proprietary ESG ratings process, an issuer whose ESG rating is considered “poor” would not meet the criteria for inclusion in the fund’s 80% test. To provide more clarity, we will revise the disclosure as follows:

“Normally investing at least 80% of assets in securities of issuers that Fidelity Management & Research Company LLC (FMR) (the Adviser) believes have proven or improving sustainability practices based on an evaluation of such issuers’ individual environmental, social, and governance (ESG) profile. In general, the Adviser favors those issuers it believes are well positioned to continue to further improve their demonstrated ESG profile in the future.”

9)

All funds

“Fund Summary” (prospectus)

“Principal Investment Strategies”

C:

The Staff requests we explain how financial performance is considered in relation to ESG.

R:

Each fund has an investment objective that is financial performance-oriented (growth of capital, etc.). Each fund seeks to achieve that objective by investing in securities that the Adviser believes have proven or improving sustainability practices. Many factors go into any manager’s decision to buy a particular security, including the security’s performance outlook and its ESG rating, so each decision to buy and sell will be based on its particular facts and circumstances.

10)

All funds

“Fund Summary” (prospectus)

“Principal Investment Strategies”

“The Adviser’s ESG ratings of issuers are derived from multiple factors, including an issuer’s environmental profile, which may include, but is not limited to, carbon and toxic emissions, water management, waste management, vulnerability to the physical impacts of climate change, and research and investment into products, services, and energies that reduce emissions and/or provide opportunities to achieve a low carbon transition. An assessment of an issuer’s social profile includes, but is not limited to, its approach to diversity and inclusion, human capital management, data privacy, product safety and human rights. With respect to governance, the independence and diversity of an issuer’s board, its compensation practices and board oversight of critical ESG issues are considered as part of the assessment. These factors are weighted based on how material the Adviser believes each factor is to an issuer’s financial outlook, and not all factors may be applicable to all issuers.”

C:

The Staff requests we confirm if this is an exhaustive list. If not, the Staff requests we make the list as comprehensive as possible.

R:

While not exhaustive, we believe the disclosure summarizes the key factors considered by the Adviser in deriving an issuer’s ESG rating.

11)

All funds

“Fund Summary” (prospectus)

“Principal Investment Strategies”

“The Adviser’s ESG ratings of issuers are derived from multiple factors, including an issuer’s environmental profile, which may include, but is not limited to, carbon and toxic emissions, water management, waste management, vulnerability to the physical impacts of climate change, and research and investment into products, services, and energies that reduce emissions and/or provide opportunities to achieve a low carbon transition. An assessment of an issuer’s social profile includes, but is not limited to, its approach to diversity and inclusion, human capital management, data privacy, product safety and human rights. With respect to governance, the independence and diversity of an issuer’s board, its compensation practices and board oversight of critical ESG issues are considered as part of the assessment. These factors are weighted based on how material the Adviser believes each factor is to an issuer’s financial outlook, and not all factors may be applicable to all issuers.”

C:

The Staff requests we explain what “low carbon transition” means.

R:

We will modify the disclosure in the “Fund Summary – Principal Investment Strategies” section as follows:

“The Adviser’s ESG ratings of issuers are derived from multiple factors, including an issuer's environmental profile, which may include, but is not limited to, carbon and toxic emissions, water management, waste management, vulnerability to the physical impacts of climate change, and research and investment into products, services, and energies that reduce emissions and/or provide opportunities to transition to less carbon-intensive products or operations achieve a low carbon transition. An assessment of an issuer’s social profile includes, but is not limited to, its approach to diversity and inclusion, human capital management, data privacy, product safety and human rights. With respect to governance, the independence and diversity of an issuer's board, its compensation practices and board oversight of critical ESG issues are considered as part of the assessment. These factors are weighted based on how material the Adviser believes each factor is to an issuer's financial outlook, and not all factors may be applicable to all issuers.”

12)

All funds

“Fund Summary” (prospectus)

“Principal Investment Risks”

“Sustainability Risk. Application of FMR’s ESG ratings process and/or its sustainable investing exclusion criteria may affect the fund’s exposure to certain issuers, sectors, regions, and countries and may affect the fund’s performance depending on whether certain investments are in or out of favor. The criteria related to the fund’s ESG ratings process and/or adherence to its sustainable investing exclusion criteria may result in the fund forgoing opportunities to buy certain securities when it might otherwise be advantageous to do so, or selling securities for ESG reasons when it might be otherwise disadvantageous

for it to do so. As a result, the fund’s performance may at times be better or worse than the performance of funds that do not use ESG or sustainability criteria. There are significant differences in interpretations of what it means for an issuer to have positive ESG factors. While the Adviser believes its definitions are reasonable, the portfolio decisions it makes may differ with other investors’ or advisers’ views.”

C:

In the “Principal Investment Risks” section in each “Fund Summary”, the Staff requests we include reference to the risk of reliance on third-party data providers for ESG.

R:

We have modified the existing disclosure under “Sustainability Risk” in “Principal Investment Risks” in the “Fund Summary” section as shown below.

“Sustainability Risk. Application of FMR’s ESG ratings process and/or its sustainable investing exclusion criteria may affect the fund’s exposure to certain issuers, sectors, regions, and countries and may affect the fund’s performance depending on whether certain investments are in or out of favor. The criteria related to the fund’s ESG ratings process and/or adherence to its sustainable investing exclusion criteria may result in the fund forgoing opportunities to buy certain securities when it might otherwise be advantageous to do so, or selling securities for ESG reasons when it might be otherwise disadvantageous for it to do so. As a result, the fund’s performance may at times be better or worse than the performance of funds that do not use ESG or sustainability criteria. There are significant differences in interpretations of what it means for an issuer to have positive ESG factors. While the Adviser believes its definitions are reasonable, the portfolio decisions it makes may differ with other investors’ or advisers’ views. When evaluating an issuer, the Adviser is dependent on information or data obtained through voluntary or third-party reporting that may be incomplete, inaccurate, or unavailable, which could cause the Adviser to incorrectly assess an issuer’s business practices.”

13)

Fidelity SAI Sustainable Future Fund

“Fund Summary” (prospectus)

“Principal Investment Risks”

“Foreign Exposure. Foreign 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.”

C:

The Staff requests we disclose if investing in emerging markets securities is a principal investment risk of the fund.

R:

Although the fund may invest in securities of foreign issuers, investment in emerging markets is not a

principal investment risk of the fund. As a result, the fund believes the current risk

disclosure is appropriate.

14)

Fidelity SAI Sustainable Future Fund

“Investment Details” (prospectus)

“Principal Investment Strategies”

“The Adviser’s proprietary ESG ratings process is designed to evaluate an issuer’s current and future ESG positioning relative to its peers. The process has two components. One component evaluates the current state of an issuer’s sustainability practices using a data-driven framework that includes proprietary and third-party (such as, CDP, Institutional Shareholder Services, and MSCI) data. Another component involves

a qualitative forward-looking assessment of an issuer’s sustainability outlook provided by the Adviser’s fundamental research analysts and ESG team. This qualitative assessment is based on criteria including, but not limited to, the issuer’s public sustainability disclosure, the issuer’s systems and policies regarding sustainability, and issuer engagement on sustainability issues and opportunities.

C:

The Staff requests we refer to “the other” component rather than “another component” since there are only two.

R:

We will make the requested change.

15)

All funds

“Investment Details” (prospectus)

“Principal Investment Strategies”

Example from Fidelity SAI Sustainable Future Fund:

“The fund is not limited to investing in securities of a specific market capitalization and may hold securities of large, medium and/or small capitalization companies.”

Example from Fidelity SAI Sustainable U.S. Equity Fund:

“In buying and selling securities for the fund, in addition to the ESG ratings process, the Adviser also relies on fundamental analysis, which involves a bottom-up assessment of an issuer’s potential for success in light of factors including its financial condition, earnings outlook, strategy, management, industry position, and economic and market conditions.”

C:

The Staff requests we disclose this information in the “Fund Summary” section as well, as applicable.

R:

The Staff has indicated that the prospectus summary section is intended to be a type of “executive summary” of