SecProbe.io

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[Dechert LLP Letterhead]

December 30, 2004

VIA EMAIL

Brion Thompson, Esq.
Division of Investment Management
Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C.  20549

Re:  UBS Investment Trust
     Post-Effective Amendment No. 38 to the Registration Statement on Form N-1A
     SEC File Nos. 33-39659 and 811-6292

Dear Mr. Thompson:

This letter responds to the Securities and Exchange Commission staff's (the
"Staff") comments that you provided to me in a telephonic discussion on
Wednesday, December 29, 2004, for the above-referenced Amendment to the
Registration Statement of UBS Investment Trust (the "Registrant"). Our summaries
of the Staff's comments, and our responses, are as follows:

MARKET TIMING DISCLOSURE

1)   COMMENT: (Prospectus, pages 17-18) You requested that the Registrant
     confirm that the risks associated with "market timing," disclosed in the
     prospectus as follows, are specific to the Registrant:

          Market timing may cause the fund to have difficulty implementing
          long-term investment strategies, because it would have more difficulty
          predicting how much cash it would need to have available to meet
          redemption requests and to invest. Market timing also may force the
          fund to sell portfolio securities at disadvantageous times to raise
          the cash needed to buy a market timer's fund shares. Market timing
          also may materially increase the fund's transaction costs,
          administrative costs or taxes. These factors may hurt the fund's
          performance and its shareholders.

     RESPONSE: The Registrant has confirmed that the market timing risks
     disclosed in its prospectus are specific to the Registrant.

2)   COMMENT: (Prospectus, pages 17-18) You stated that the "market timing"
     disclosure was permissive in nature (E.G., use of the term "may" rather
     than "will"), and therefore additional risk disclosure must be added to
     notify investors/prospective investors that there is a possibility that
     certain persons may be

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     able to "market time" the fund by virtue of the fact that the Registrant's
     policies and procedures may not apply in all instances to all persons.

     RESPONSE: The Registrant will amend the relevant "market timing" disclosure
     to remove any permissive language by using the term "will" in place of the
     term "may."

3)   COMMENT: (Prospectus, pages 17-18) You referred to Item 6(e)(4)(iii) of
     Form N-1A and requested that the Registrant describe whether the
     restrictions imposed by the Registrant to prevent or minimize frequent
     purchases and redemptions apply uniformly in all cases or whether the
     restrictions will not be imposed under certain circumstances. You asked
     that the Registrant specify those circumstances, if any, in which the
     restrictions will not apply to all categories of persons.

     RESPONSE: The Registrant's "market timing" restrictions and prevention
     procedures apply uniformly to all categories of persons, except in the case
     of omnibus accounts, as is currently explained in the prospectus. Certain
     types of transactions will also be exempt from the market timing prevention
     procedures such as purchases and redemptions through UBS Global Asset
     Management (US) Inc.'s automatic cash withdrawal plan and automatic
     investment plan, and purchases and redemptions by wrap-fee accounts that
     have an automatic rebalancing feature. The Registrant does not currently
     disclose this in the prospectus, but will do so.

FAIR VALUE PRICING DISCLOSURE

4)   COMMENT: (Prospectus, pages 20-21) You stated that the following prospectus
     disclosure was permissive in nature:

          If the fund concludes that a market quotation is not readily available
          for a fund's portfolio security for any number of reasons, including
          the occurrence of a "significant event" (E.G., natural disaster or
          governmental action), after the close of trading in its principal
          market but before the close of regular trading on the NYSE, the fund
          MAY use fair value methods to reflect those events. (emphasis added)

     Given this permissive language, you requested that the Registrant disclose
     the circumstances in which the fund would NOT use fair value methods to
     price a portfolio security when a market quotation was not readily
     available.

     RESPONSE: The Registrant will amend the relevant "fair value" pricing
     disclosure to remove the permissive language by using the term "will" in
     place of the term "may."

PORTFOLIO HOLDINGS DISCLOSURE

5)   COMMENT: (Prospectus, pages 5-6) You stated that the following prospectus
     disclosure was not specific and that the disclosure should reflect what the
     Registrant is currently doing, not what it may do:

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          UBS Global AM will GENERALLY post on its website at www.ubs.com the
          ten largest stock portfolio holdings of the fund, and the percentage
          that each of these holdings represents of the fund's total assets, as
          of the most recent calendar-quarter end, 14 calendar days after the
          end of the calendar quarter. (emphasis added)

     RESPONSE: The Registrant will amend the relevant "portfolio holdings"
     disclosure to remove the non-specific language by deleting the phrase "will
     generally post" and inserting the phrase "will post."

6)   COMMENT: (Prospectus, pages 5-6) You referenced Item 11(f)(2), Instruction
     3(b)(2) and requested that the Registrant disclose how long information
     regarding its ten largest stock portfolio holdings will be posted on the
     UBS Global AM website at www.ubs.com.

     RESPONSE: The Registrant will add the following statement to its prospectus
     disclosure:

          The ten largest stock portfolio holdings of the fund will remain
          available on the UBS Global AM website, www.ubs.com, at least until
          the date on which the fund files its Form N-CSR or Form N-Q with the
          SEC for the period that relates to such website information.

7)   COMMENT: (SAI, pages 22-24) You inquired as to whether the section entitled
     "Board Oversight" applies to each of the disclosure scenarios discussed in
     the "portfolio holdings" disclosure (I.E., "Ten Largest Stock Holdings --
     Online Disclosure," "Complete Portfolio Holdings -- Disclosure to Service
     Providers Subject to Confidentiality and Trading Restrictions," ETC.).

     RESPONSE: The section entitled "Board Oversight" applies to each of the
     disclosure scenarios discussed in the "portfolio holdings" disclosure. The
     Registrant will amend its SAI to reflect such application.

8)   COMMENT: (SAI, pages 22-24) You asked that the Registrant clarify the
     following SAI disclosure with respect to the online disclosure of its ten
     largest stock holdings:

          The fund GENERALLY WILL SEEK TO disclose its ten largest stock
          portfolio holdings and the percentages that each of these ten largest
          stock portfolio holdings represent of the fund's total assets ("ten
          largest stock holdings") as of the most recent calendar-quarter end
          online at www.ubs.com, 14 calendar days after the end of the calendar
          quarter. (emphasis added)

     RESPONSE: The Registrant will clarify the relevant "portfolio holdings"
     disclosure by deleting the phrase "generally will seek to" and inserting
     the term "will."

9)   COMMENT: (SAI, pages 22-24) You referenced Item 11(f)(1)(vi) of Form N-1A
     and requested that the Registrant describe the procedures that it uses to
     ensure that the disclosure of information about the portfolio securities is
     for legitimate business

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     purposes and in the best interests of the Registrant's shareholders,
     including procedures to address conflicts between the interests of the
     shareholders, on the one hand and those of the fund's investment adviser,
     principal underwriter, or any affiliated person of the Registrant, its
     investment adviser or its principal underwriter, on the other. You also
     requested that the Registrant describe the procedures used to monitor the
     use of portfolio holdings information.

     RESPONSE: The Registrant will add the following disclosure to the SAI
     following the second paragraph in the section entitled "Policies and
     Procedures Generally:"

          UBS Global AM's procedures require that UBS Global AM Legal and
          Compliance address any material conflicts of interest regarding a
          disclosure of portfolio holdings and determine whether a disclosure of
          the fund's portfolio holdings is for a legitimate business purpose and
          in the best interests of the fund's shareholders prior to the fund's
          officer or UBS Global AM Legal authorizing the disclosure of portfolio
          holdings. UBS Global AM Legal and Compliance will periodically review
          how the fund's portfolio holdings are being disclosed to and used by,
          if at all, service providers, UBS Global AM affiliates and certain
          fiduciaries, and broker-dealers to ensure that such use is for
          legitimate business reasons and in the best interests of the fund's
          shareholders.

10)  COMMENT: (SAI, pages 22-24) (Section entitled "Complete Portfolio Holdings
     -- Disclosure to Service Providers Subject to Confidentiality and Trading
     Restrictions") You referenced Item 11(f)(2) of Form N-1A and requested that
     the Registrant disclose any ongoing arrangements to make available
     information about the Registrant's portfolio securities to any person. You
     stated that it is the Staff's position that any formal or informal
     arrangement whereby the Registrant provides a regular and continuous flow
     of information to a third party (E.G., Morningstar, custodian, ETC.)
     regarding the Registrant's portfolio holdings would be considered an
     "ongoing arrangement" which must be described in the Registrant's
     "portfolio holdings" SAI disclosure. Therefore, you requested that the
     Registrant list any service providers to whom the Registrant's portfolio
     holdings are disclosed as part of ongoing arrangements.

     RESPONSE: The following disclosure will be added to the SAI in the section
     entitled "Complete Portfolio Holdings -- Disclosure to Service Providers
     Subject to Confidentiality and Trading Restrictions:"

          As of December 1, 2004, the fund's complete portfolio holdings are
          disclosed to the Service Providers listed below as part of ongoing
          arrangement(s) that serve legitimate business purposes.

          State Street Bank and Trust Company ("State Street"). The fund
          discloses its complete portfolio holdings to its custodian, State
          Street, on an ongoing basis, and there is no lag between the date of
          portfolio

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          holding information and the date on which the information is disclosed
          to State Street.

          Thompson Corporation. The fund discloses its complete portfolio
          holdings to Thompson Corporation so that it may assist the fund in
          production of its quarterly fact sheet on a quarterly basis. There is
          a 1 day lag between the date of portfolio holding information and the
          date on which the information is disclosed to State Street.

          Ernst & Young LLP ("Ernst &Young"). The fund discloses its complete
          portfolio holdings to Ernst & Young, the Fund's independent registered
          public accounting firm, on an annual and semi-annual basis, for
          reporting purposes. There is 30 day lag between the date of portfolio
          holding information and the date on which the information is disclosed
          to Ernst & Young. The fund also discloses its complete portfolio
          holdings to Ernst & Young once a year at a month-end, for annual audit
          purposes. In this case, there is no lag between the date of portfolio
          holding information and the date on which the information is disclosed
          to Ernst & Young.

          Morningstar, Standard and Poor's and Lipper. The fund discloses its
          complete portfolio holdings to these three rating agencies on a
          monthly basis so that the fund may be included in each rating agency's
          industry reports and other materials. There is 30 day lag between the
          date of portfolio holding information and the date on which the
          information is disclosed to the rating agencies.

11)  COMMENT: (SAI, pages 22-24) (Section entitled "Complete and Partial
     Portfolio Holdings -- Disclosure as Required by Applicable Law") You
     requested that disclosure be added to the SAI regarding who authorizes the
     disclosure of portfolio holdings information when required for a legal or
     regulatory purpose. You also asked that the Registrant disclose how such
     disclosure is monitored by the fund to ensure that its use does not present
     a material conflict of interest and is in the best interest of the
     Registrant's shareholders.

     RESPONSE: The Registrant will add the following disclosure to the section
     entitled "Complete and Partial Portfolio Holdings -- Disclosure as Required
     by Applicable Law":

          UBS Global AM Legal must authorize the disclosure of portfolio
          holdings information when required for a legal or regulatory purpose.
          UBS Global AM Legal may not be able to prevent or place restrictions
          on the disclosure of the fund's portfolio holdings when compelled by
          law or regulation to provide such information, even if UBS Global AM
          Legal determines that such disclosure may not be in the best interest
          of fund shareholders or that a material conflict of interest is
          present or appears to be present. However, UBS Global AM Legal will
          attempt to monitor the

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          use of any fund portfolio holdings information disclosed as required
          by law or regulation.

12)  COMMENT: (SAI, pages 22-24) (Section entitled "Disclosure of Non-Material
     Information") You stated that the term "other UBS Global AM
     representatives" as used in the following disclosure is too broad and
     requested that such representatives be described with more specificity:

          Policies and procedures regarding non-material information permit UBS
          Global AM fund officers, UBS Global AM fund portfolio managers, and
          OTHER UBS GLOBAL AM REPRESENTATIVES (collectively, "Approved
          Representatives") to disclose any views, opinions, judgments, advice
          or commentary, or any analytical, statistical, performance or other
          information...(emphasis added)

     RESPONSE: The Registrant has amended the relevant disclosure to delete the
     term "other UBS Global AM representatives" and insert the following phrase:
     "senior officers of UBS Global AM Finance, Compliance and Legal."

13)  COMMENT: (SAI, pages 22-24) (Section entitled "Disclosure of Non-Material
     Information") You stated that this section is too broad and that there
     should be no distinction between material and non-material portfolio
     holdings information. Therefore, you asked that this section be revised
     accordingly.

     RESPONSE: The Registrant has revised the section entitled "Disclosure of
     Non-Material Information" to reflect the followin