SecProbe.io

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                      Morgan Stanley Global Advantage Fund
                           1221 Avenue of the Americas
                               New York, NY 10020

September 29, 2005

Securities and Exchange Commission
Judiciary Plaza
100 F Street, NE
Washington, DC 20549

Attention:  Larry Greene, Division of Investment Management
            Mail Stop 0505

RE:  MORGAN STANLEY GLOBAL ADVANTAGE FUND
     (FILE NOS. 333-38297 AND 811-8455)

Dear Mr. Greene:

Thank you for your telephonic comments regarding the registration statement on
Form N-1A for Morgan Stanley Global Advantage Fund (the "Fund") filed with the
Securities and Exchange Commission on July 28, 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
12 to the Fund's registration statement on Form N-1A, which will be filed via
EDGAR on or about September 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 THE PROSPECTUS

COMMENT 3.   AS REQUIRED BY ITEM 4(b)(2) OF FORM N-1A, PLEASE INCLUDE A
             DISCUSSION OF THE INVESTMENT ADVISER'S CONSIDERATIONS WHEN DECIDING
             WHICH PORTFOLIO SECURITIES TO SELL.

                    RESPONSE 3. The relevant disclosure is currently included in
                    the third sentence of the second paragraph of the section
                    titled "Principal Investment Strategies."

COMMENT 4.   IF THE FUND MAY INVEST IN CONVERTIBLE SECURITIES RATED LOWER THAN
             INVESTMENT GRADE, PLEASE STATE SO IN THE PROSPECTUS.

                    RESPONSE 4. The Fund may invest up to 5% of its net assets
                    in convertible securities rated below investment grade.
                    Because investments in these securities are not a "principal
                    investment strategy" of the Fund as defined in Item 4 of
                    Form N-1A, the Fund has disclosed its ability to invest in
                    convertible securities rated below investment grade in its
                    Statement of Additional Information.

COMMENT 5.   CONSIDER INCLUDING THE ORDER PROCESSING FEE IN THE FEE TABLE OR AS
             A FOOTNOTE TO THE FEE TABLE AND IN THE EXAMPLE.

                    RESPONSE 5. 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 6.   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 6. Such a description does not appear on the Fund's
                    website.

COMMENT 7.   HAVE FUND SHAREHOLDERS APPROVED THE AMENDED AND RESTATED INVESTMENT
             ADVISORY AGREEMENT?

                    RESPONSE 7. 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.

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COMMENT 8.   CONSIDER ADDING ADDITIONAL DISCLOSURE REGARDING FAIR VALUATION TO
             THE SECTION "PRICING FUND SHARES".

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

COMMENT 9.   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 9. 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.

COMMENT 10.  CONSIDER ADDING ADDITIONAL DISCLOSURE REGARDING REVENUE SHARING TO
             THE SECTION "ADDITIONAL INFORMATION".

                    RESPONSE 10. We respectfully acknowledge the comment, but
                    believe the current disclosure is sufficient.

COMMENT 11.  IN THE SECTION TITLED "FUND MANAGEMENT", (1) PLEASE CLARIFY
             WHETHER THERE ARE MEMBERS OF THE PORTFOLIO MANAGEMENT TEAM THAT ARE
             INVOLVED WITH THE MANAGEMENT OF THE FUND THAT ARE NOT DISCLOSED IN
             THE PROSPECTUS, AND (2) EXPLAIN SUPPLEMENTALLY WHETHER THE
             FOLLOWING SENTENCE IS CONSISTENT WITH ITEM 5(a)(2) AND ITEM 15(a)
             OF FORM N-1A: "THE COMPOSITION OF THE PORTFOLIO MANAGEMENT TEAM MAY
             CHANGE WITHOUT NOTICE FROM TIME TO TIME."

                    RESPONSE 11. Item 5(a)(2) requires disclosure of the persons
                    "primarily responsible for the day-to-day management of the
                    Fund's portfolio" 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 of persons who are "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 to the extent that a team member
                    with primary

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                    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.

COMMENT 12.  PLEASE NOTE THAT THE SIDEBAR ON PAGE 1 AND PAGE 5 APPEARS IN ALL
             CAPS IN THE EDGAR FILINGS WITH THE COMMISSION AND CONFIRM THAT IT
             IS NOT IN ALL CAPS AS IT APPEARS IN THE PRINTED PROSPECTUS.

                    RESPONSE 12. This disclosure appears in italics in the
                    Fund's printed prospectus, not all caps.

             COMMENTS TO THE SAI

COMMENT 13.  IN THE SECTION ENTITLED "FUND MANAGEMENT - PORTFOLIO MANAGER
             COMPENSATION STRUCTURE," (1) INCLUDE ONLY THE DISCRETIONARY
             COMPENSATION RECEIVED BY THE PORTFOLIO MANAGERS OF THE FUND DURING
             THE LAST YEAR AND (2) CONFIRM THAT YOU ARE PROVIDING THE REQUESTED
             INFORMATION.

                    RESPONSE 13. We believe the current disclosure is in
                    compliance with SEC Release 2004-89. This 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. Please note that
                    we revised the disclosure to clarify that investment
                    performance, upon which a portfolio manager's compensation
                    is linked, is calculated for one-, three-, and five-year
                    periods measured against a fund's/account's primary
                    benchmark, indices and/or peer groups, where applicable.

COMMENT 14.  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 14. 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.

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                    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.

As you have requested and consistent with SEC 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 the Staff do not foreclose the Commission from taking
any action with respect to the filings; and

-    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 any of these responses in further detail or if you
have any questions, please feel free to contact me at (212) 762-5481. Thank you.

Sincerely,

/s/ Debra Rubano

Debra Rubano

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