SEC Company Response from MORGAN STANLEY INFORMATION FUND (CIK 0000934540) — Aug 1, 2005
MORGAN STANLEY INFORMATION FUND (CIK 0000934540)
Date: Aug. 1, 2005 · CIK: 0000934540 · Accession: 0000950136-05-004474
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Morgan Stanley Information Fund
1221 Avenue of the Americas
New York, NY 10020
August 1, 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 INFORMATION FUND
(FILE NO. 33-87472)
Dear Mr. Greene:
Thank you for your additional telephonic comment of July 28, 2005 regarding the
registration statement on Form N-1A for Morgan Stanley Information Fund (the
"Fund") filed with the Securities and Exchange Commission on May 26, 2005.
Below, we provide our response to the Staff's comment, as requested.
COMMENT 1. PLEASE SUPPLEMENTALLY EXPLAIN HOW THE FOLLOWING STATEMENT
INCLUDED ON PAGE 1 OF THE PROSPECTUS IS CONSISTENT WITH THE 50%
TEST THAT IS APPLIED TO INVESTMENT COMPANIES THAT INVEST IN A
SPECIFIC COUNTRY OR REGION: "A COMPANY IS CONSIDERED TO BE IN THE
COMMUNICATIONS AND INFORMATION INDUSTRY IF IT DERIVES AT LEAST
35% OF ITS REVENUES OR EARNINGS FROM, OR DEVOTES AT LEAST 35% OF
ITS ASSETS TO DESIGNING, DEVELOPING, MANUFACTURING, PROVIDING OR
ENABLING THE FOLLOWING PRODUCTS AND SERVICES: REGULAR TELEPHONE
SERVICE; COMMUNICATIONS EQUIPMENT AND SERVICES;..."
Response 1. Release No. IC-24828 states that "if an
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investment company uses a criterion that requires qualifying
investments to be in issuers that derive a specified
proportion of their revenues or profits from goods produced
or sold, investments made, or services performed in the
applicable country or region, or that have a specified
proportion of their assets in that country or region, the
[Securities and Exchange Commission], consistent with its
current position, would expect the proportion used to be at
least 50%, in order for the investments to be deemed to be
tied economically to the country or region." This
restriction is applied to investment companies that have
names that indicate an investment emphasis in certain
countries or geographical regions and is not applied to
investment companies that have names that indicate an
investment emphasis in certain investments or industries.
Therefore, we respectfully acknowledge your comment, but
believe that the disclosure as stated and applied to the
Fund is sufficient.
As you have requested and consistent with SEC Press Release 2004-89, the Fund
hereby acknowledges that:
o the Fund is responsible for the adequacy and accuracy of the disclosure in
the filings;
o the Staff's comments or changes to disclosure in response to Staff comments
in the filings reviewed by the Staff do not foreclose the Commission from
taking any action with respect to the filings; and
o the Fund may not assert Staff comments as a defense in any proceeding
initiated by the Commission or any person under the federal securities laws
of the United States.
If you would like to discuss this response in further detail or if you have any
questions, please feel free to contact me at (630) 684-6301. Thank you.
Sincerely,
/s/ Elizabeth Nelson
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Elizabeth Nelson