SecProbe.io

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                Morgan Stanley Global Dividend Growth Securities
                           1221 Avenue of the Americas
                               New York, NY 10020

July 29, 2005

Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C.  20549
Attention:  Larry Greene, Division of Investment Management
            Mail Stop 0505

RE:  MORGAN STANLEY GLOBAL DIVIDEND GROWTH SECURITIES
     (FILE NO. 33-59004)

Dear Mr. Greene:

Thank you for your telephonic comments regarding the registration statement on
Form N-1A for Morgan Stanley Global Dividend Growth Securities (the "Fund")
filed with the Securities and Exchange Commission on May 26, 2005. Below, we
describe the changes made to the registration statement in response to the
Staff's comments and provide any responses to or any supplemental explanations
of such comments, as requested. These changes will be reflected in
post-effective amendment number 6 to the Fund's registration statement on Form
N-1A, which will be filed via EDGAR on or about July 29, 2005.

             GENERAL COMMENTS TO FORM N-1A

COMMENT 1.   PLEASE CONFIRM THAT THE FUND IS COMPLYING WITH THE PRIVACY POLICY
             NOTIFICATION REQUIREMENTS OF THE GRAMM-LEACH-BLILEY ACT AND
             DISTRIBUTING ITS PRIVACY POLICY TO INVESTORS.

                    RESPONSE 1. The Fund provides its privacy policy annually in
                    accordance with the requirements of Regulation S-P.

COMMENT 2.   PLEASE CONFIRM THAT THE REGISTRATION STATEMENT INCLUDES THE
             ANTI-MONEY LAUNDERING AND CUSTOMER VERIFICATION DISCLOSURE REQUIRED
             BY THE U.S. PATRIOT ACT.

                    RESPONSE 2. The requisite notice of the customer
                    identification verification policy is disclosed in the
                    account application form. Anti-money laundering and customer
                    verification disclosure is also included under the
                    "Shareholder Information-How to Buy Shares" section of the
                    Fund's prospectus.

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             COMMENTS TO PROSPECTUS

COMMENT 3.   PLEASE NOTE THAT THE FOLLOWING DISCLOSURE IS IN ALL CAPS IN THE
             EDGAR FILING WITH THE COMMISSION AND CONFIRM THAT IT IS NOT IN ALL
             CAPS AS IT APPEARS IN THE PRINTED PROSPECTUS:

             "The Securities and Exchange Commission has not approved or
             disapproved these securities or passed upon the adequacy of this
             PROSPECTUS. Any representation to the contrary is a criminal
             offense."

                    RESPONSE 3. This sentence appears in bold type, not all
                    caps.

COMMENT 4.   ON PAGE 1 OF THE PROSPECTUS, IT IS STATED THAT "[T]HE FUND WILL
             NORMALLY INVEST AT LEAST 80% OF ITS ASSETS IN DIVIDEND PAYING
             EQUITY SECURITIES OF COMPANIES LOCATED IN VARIOUS COUNTRIES AROUND
             THE WORLD" AND THAT THE FUND'S SUB-ADVISER "SEEKS INVESTMENTS
             PRIMARILY IN COMMON STOCKS (INCLUDING DEPOSITORY RECEIPTS) OF
             COMPANIES WITH A RECORD OF PAYING DIVIDENDS AND POTENTIAL FOR
             INCREASING DIVIDENDS." PLEASE CLARIFY WHETHER THE FUND WILL INVEST
             PRIMARILY IN COMMON STOCKS OR EQUITY SECURITIES.

                    RESPONSE 4. The Fund invests at least 80% of its assets in
                    dividend-paying equity securities. The Fund's equity
                    security investments consist primarily of common stocks that
                    pay dividends. We believe the current disclosure is
                    sufficient.

COMMENT 5.   TO THE EXTENT THAT THE FUND INVESTS IN CONVERTIBLE SECURITIES RATED
             BELOW INVESTMENT GRADE, PLEASE INCLUDE THE RELEVANT RISK
             DISCLOSURE.

                    RESPONSE 5. The relevant risk disclosure is included in the
                    Prospectus section entitled "Principal Risks."

COMMENT 6.   ADD LANGUAGE REGARDING THE CIRCUMSTANCES UNDER WHICH THE ADVISER
             WILL MOVE TO SELL SECURITIES.

                    RESPONSE 6. The relevant disclosure has been added.

COMMENT 7.   CONSIDER INCLUDING THE ORDER PROCESSING FEE IN THE FEE TABLE OR AS
             A FOOTNOTE TO THE FEE TABLE AND IN THE EXAMPLE.

                    RESPONSE 7. The Order Processing Fee is not a fee imposed by
                    the Fund. It is a fee that Morgan Stanley DW Inc. charges
                    its clients. Therefore, it should not be included in the fee
                    table, as a footnote to the fee table or in the Example.

COMMENT 8.   WITH RESPECT TO THE FUND'S TEMPORARY DEFENSIVE STRATEGY DESCRIBED
             ON PAGE 6, PLEASE INDICATE THAT THIS STRATEGY MAY BE INCONSISTENT
             WITH THE FUND'S PRINCIPAL INVESTMENT STRATEGIES AND DISCLOSE THE
             EFFECT OF TAKING SUCH A TEMPORARY DEFENSIVE POSITION - THAT THE
             FUND MAY NOT ACHIEVE ITS INVESTMENT OBJECTIVE.

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                    RESPONSE 8. We respectfully acknowledge the comment, but
                    believe the current disclosure is sufficient.

COMMENT 9.   IF A DESCRIPTION OF THE FUND'S POLICIES AND PROCEDURES WITH RESPECT
             TO THE DISCLOSURE OF THE FUND'S PORTFOLIO SECURITIES IS AVAILABLE
             ON THE FUND'S WEBSITE, PLEASE SO STATE IN THE PROSPECTUS.

                    RESPONSE 9. Such a description does not appear on the Fund's
                    website.

COMMENT 10.  HAVE FUND SHAREHOLDERS APPROVED THE AMENDED AND RESTATED INVESTMENT
             ADVISORY AGREEMENT?

                    RESPONSE 10. The Fund's investment advisory agreement was
                    amended and restated to remove the administrative services
                    component from the Management Agreement and to reduce the
                    investment advisory fee. The administrative services
                    previously provided to the Fund by the Investment Adviser
                    are being provided by Morgan Stanley Services Company Inc.
                    ("Administrator") pursuant to a separate administration
                    agreement entered into by the Fund with the Administrator.
                    Such change resulted in a reduction in the advisory fee
                    concurrent with the implementation of an administration fee
                    equal to the amount of the advisory fee reduction pursuant
                    to the new administration agreement. Shareholder approval
                    was not required.

COMMENT 11.  CONSIDER ADDING ADDITIONAL DISCLOSURE REGARDING FAIR VALUATION TO
             THE SECTION "PRICING FUND SHARES".

                    RESPONSE 11. We respectfully acknowledge the comment, but
                    believe the current disclosure is sufficient.

COMMENT 12.  SUPPLEMENTALLY DISCUSS WHETHER WRITTEN NOTICE WITH RESPECT TO THE
             FUND'S POLICY "TO REJECT, LIMIT OR PROHIBIT EXCHANGES WITHOUT PRIOR
             NOTICE, AT ITS SOLE DISCRETION ..." SET FORTH IN THE "LIMITATIONS
             ON EXCHANGES" SECTION OF THE PROSPECTUS HAS BEEN ADEQUATELY
             PROVIDED TO INVESTORS IN ACCORDANCE WITH RULE 11a-3. CLARIFY THAT
             THE FUND WOULD ONLY REJECT THE PURCHASE PORTION OF AN EXCHANGE
             REQUEST.

                    RESPONSE 12. The Fund's ability to reject, limit or prohibit
                    exchanges is designed to offer the Fund flexibility to
                    address market timing abuses as they occur. The Release
                    adopting the rules requiring enhanced market timing
                    disclosure specifically authorizes such a policy provided it
                    is disclosed in the Fund's prospectus. Further, written
                    notice of the policy, as disclosed in the Fund's prospectus,
                    is consistent with the provisions of Rule 11a-3(b)(6)(ii).
                    Exchange requests consist of a redemption of Fund shares and
                    a simultaneous purchase of another fund's shares. The Fund
                    reserves the right to reject any exchange request for any
                    reason. The Fund would not reject a valid redemption
                    request.

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COMMENT 13.  IN THE "HOW TO EXCHANGE SHARES - EXCHANGE PROCEDURES" SECTION,
             PLEASE REPLACE THE WORD "ACCEPTED" WITH "RECEIVED" OR ANOTHER TERM
             TO THAT EFFECT, IN ACCORDANCE WITH RULE 22c-1, WITH RESPECT TO THE
             FOLLOWING SENTENCE: "AN EXCHANGE TO ANY MORGAN STANLEY FUND (EXCEPT
             A MONEY MARKET FUND) IS MADE ON THE BASIS OF THE NEXT CALCULATED
             NET ASSET VALUES OF THE FUNDS INVOLVED AFTER THE EXCHANGE
             INSTRUCTIONS ARE ACCEPTED." [EMPHASIS ADDED]

                    RESPONSE 13. The disclosure has been so revised.

COMMENT 14.  CONSIDER ADDING ADDITIONAL DISCLOSURE REGARDING REVENUE SHARING TO
             THE SECTION "ADDITIONAL INFORMATION".

                    RESPONSE 14. We respectfully acknowledge the comment, but
                    believe the current disclosure is sufficient.

COMMENT 15.  CONFIRM THAT THE ANNUAL DISTRIBUTION AND SHAREHOLDER SERVICES
             (12b-1) FEES PAYABLE BY THE FUND'S CLASSES WILL NOT EXCEED THE
             LIMITATIONS UNDER THE RULES OF THE NATIONAL ASSOCIATION OF
             SECURITIES DEALERS (NASD) RELATING TO "SERVICE FEES" AND
             "ASSET-BASED SALES CHARGES."

                    RESPONSE 15. The Fund complies with the limitations under
                    the NASD Rules relating to "service fees" and "asset-based
                    sales charges."

COMMENT 16.  EXPLAIN SUPPLEMENTALLY WHETHER THE FOLLOWING SENTENCE INCLUDED
             UNDER "FUND - FUND MANAGEMENT" IS CONSISTENT WITH ITEM 5(a)(2) AND
             ITEM 15(a) OF FORM N-1A: "THE COMPOSITION OF THE TEAM MAY CHANGE
             WITHOUT NOTICE FROM TIME TO TIME."

                    RESPONSE 16. Item 5(a)(2) requires disclosure of the persons
                    "primarily responsible for the day-to-day management of the
                    Fund's portfolio ("Portfolio Manager")," and Item 15(a)
                    requires certain disclosure regarding such persons'
                    management of other accounts. The Fund is managed by a team
                    of investment professionals. The team may be comprised both
                    of persons "primarily responsible for the day-to-day
                    management of the Fund's portfolio" (any such persons are
                    disclosed under Item 5(a)(2) and Item 15 (a)) and persons
                    who are not. The referenced disclosure states that the
                    composition of the team may change without notice from time
                    to time. We note supplementally that, notwithstanding this
                    disclosure, to the extent that a team member with primary
                    responsibility for the day-to-day management of the Fund's
                    portfolio changes, the Fund intends to supplement its
                    Prospectus and its Statement of Additional Information with
                    the information required by Item 5(a)(2) and Item 15(a) for
                    such team member.

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             COMMENTS TO SAI

COMMENT 17.  PLEASE CONFIRM THAT THE REGISTRATION STATEMENT INCLUDES APPLICABLE
             DISCLOSURE REGARDING "SEGREGATING ASSETS" IN CONNECTION WITH THE
             FUND'S USE OF DERIVATIVES.

                    RESPONSE 17. The applicable disclosure is included in the
                    Fund's SAI.

COMMENT 18.  IN THE SECTION ENTITLED "FUND MANAGEMENT - PORTFOLIO MANAGER
             COMPENSATION STRUCTURE," INCLUDE ONLY THE DISCRETIONARY
             COMPENSATION RECEIVED BY THE PORTFOLIO MANAGERS OF THE FUND DURING
             THE LAST YEAR.

                    RESPONSE 18. We believe the current disclosure is in
                    compliance with SEC Release 2004-89. The Release requires
                    that the SAI include disclosure regarding the structure of,
                    and the method used to determine, the compensation of its
                    portfolio managers. The Release notes that the purpose of
                    this disclosure is to help investors better understand a
                    portfolio manager's incentives in managing a fund and shed
                    light on possible conflicts of interest that could arise
                    when a portfolio manager manages other accounts. Therefore,
                    in order to achieve this purpose, the disclosure, in our
                    view, should include all possible forms of compensation that
                    are available to the portfolio manager in connection with
                    managing the portfolio and other accounts.

COMMENT 19.  PLEASE REVISE THE "DISCLOSURE OF PORTFOLIO HOLDINGS" SECTION TO (i)
             CLARIFY WHAT TIME LAG THERE IS WITH RESPECT TO DISSEMINATION OF
             PUBLIC PORTFOLIO HOLDINGS INFORMATION, (ii) CLARIFY WHICH
             EXEMPTIONS AND EXCEPTIONS TO THE POLICY EXIST AND (iii) INCLUDE AN
             EXHAUSTIVE LIST OF THOSE PERSONS WHO MAY RECEIVE NON-PUBLIC
             PORTFOLIO HOLDINGS INFORMATION WITHOUT ENTERING INTO A
             NON-DISCLOSURE AGREEMENT. PLEASE SUPPLEMENTALLY DISCUSS WHY PERSONS
             WHO OWE A DUTY OF TRUST OR CONFIDENCE TO THE FUND MAY RECEIVE
             NON-PUBLIC PORTFOLIO HOLDINGS INFORMATION WITHOUT ENTERING INTO A
             NON-DISCLOSURE AGREEMENT. PLEASE PROVIDE A LIST OF ALL ONGOING
             ARRANGEMENTS.

                    RESPONSE 19. With respect to clause (i), we respectfully
                    acknowledge the comment, but believe the current disclosure
                    is sufficient. With respect to clauses (ii) and (iii), the
                    disclosure has been so revised. Persons who owe a duty of
                    trust or confidence to the Fund (such as lawyers and
                    accountants) have non-disclosure obligations with respect to
                    many kinds of information concerning the Fund, including
                    non-public portfolio holdings information. Requiring such
                    persons to enter into a non-disclosure agreement would be
                    redundant. A current list of all ongoing arrangements has
                    been added to the definitive SAI.

COMMENT 20.  PROVIDE FURTHER FUND SPECIFIC DISCLOSURE PURSUANT TO ITEM 12(b)(10)
             OF FORM N-1A.

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                    RESPONSE 20. Additional disclosure has been added to the SAI
                    in compliance with Item 12(b)(10) of Form N-1A.

COMMENT 21.  IN THE SECTION ENTITLED "MANAGEMENT OF THE FUND - MANAGEMENT
             INFORMATION" IN THE PARAGRAPH THAT BEGINS "THE FUND DOES NOT HAVE A
             SEPARATE NOMINATING COMMITTEE....," THE LAST SENTENCE OF SUCH
             PARAGRAPH STATES "NOMINATIONS FROM SHAREHOLDERS SHOULD BE IN
             WRITING AND SENT TO THE INDEPENDENT TRUSTEES AS DESCRIBED BELOW."
             PLEASE REVISE THE DISCLOSURE TO MAKE CLEAR WHAT IS MEANT BY "AS
             DESCRIBED BELOW."

                    RESPONSE 21. The disclosure has been revised to read as
                    follows: Nominations from shareholders should be in writing
                    and sent to the Independent Trustees as described below
                    under the caption "Shareholder Communications."

As you have requested and consistent with SEC Press Release 2004-89, the Fund
hereby acknowledges that:
-      the Fund is responsible for the adequacy and accuracy of the disclosure
in the filings;
-      the Staff's comments or changes to disclosure in response to Staff
comments in the filings reviewed by