SecProbe.io

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<TYPE>LETTER
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<FILENAME>filename1.txt
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									December 2, 2004

Matthew N. Shea, Esq.
Ropes & Gray LLP
One International Place
Boston, Massachusetts  02110

Re:	PIMCO Floating Rate Strategy Fund
	File Nos. 333-120227 and 811-21601

Dear Mr. Shea:

	On November 4, 2004, PIMCO Floating Rate Strategy Fund filed
a
registration statement on Form N-2 in connection with the proposed
offering of preferred shares.  In a letter dated November 19,
2004,
you represented that this filing is substantially similar to the
information contained in an earlier registration statement on Form
N-
2 filed by the fund, which the Commission declared effective on
October 26, 2004 (File No. 333-117187).  You state further that
this
filing is substantially similar to another registration statement
on
Form N-2 involving the offering of preferred shares filed by PIMCO
Floating Rate Income Fund, which the Commission declared effective
on
October 28, 2003 (File No. 333-108475).   Based upon the
similarity
of the previous filings, you requested selective review of the
registration statement.  Accordingly, we have limited our review
of
the filing.  We have the following comments.  For convenience, we
generally organized our comments using the headings and page
numbers
in your registration statement.

Prospectus

Use of Proceeds, page 15

1. The third sentence states that the fund will invest
substantially
all of the net proceeds of the offering within 6 months.  Please
explain in this section the reasons for the expected delay and the
consequences of such a delay.  See Item 7.2 and Guide 1 to Form N-
2.

General Comments

2. Where a comment is made in one location, it is applicable to
all
similar disclosure appearing elsewhere in the registration
statement.

3. We note that portions of the filing are incomplete.  We may
have
additional comments on such portions when you complete them in a
pre-
effective amendment, on disclosures made in response to this
letter,
on information supplied supplementally, or on exhibits in any
further
pre-effective amendments.

4. If the fund intends to rely on Rule 430A of the Securities Act
of
1933 to omit certain information from the prospectus, please
identify
the omitted information to us supplementally.

5. Please advise us if you have submitted or expect to submit an
exemptive application or no-action request in connection with the
registration statement.

6. Please respond to this letter in the form of a pre-effective
amendment filed pursuant to rule 472 under the Securities Act of
1933.  You should provide a response to all comments.  Where no
change is made in the filing in response to a comment, please so
indicate in a supplemental letter for the information of the staff
and state briefly the basis for such position.  Please note the
rule
472 requirement for copies marked to show changes from the
previous
filing.

*    *    *    *    *    *

	We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings reviewed by the staff to
be
certain that they have provided all information investors require
for
an informed decision.  Since the fund and its management are in
possession of all facts relating to the fund`s disclosure, they
are
responsible for the accuracy and adequacy of the disclosures they
have made.

	Notwithstanding our comments, in the event the fund requests
acceleration of the effective date of the pending registration
statement, it should furnish a letter, at the time of such
request,
acknowledging that

* should the Commission or the staff, acting pursuant to delegated
authority, declare the filing effective, it does not foreclose the
Commission from taking any action with respect to the filing;
* the action of the Commission or the staff, acting pursuant to
delegated authority, in declaring the filing effective, does not
relieve the fund from its full responsibility for the adequacy and
accuracy of the disclosure in the filing; and
* the fund may not assert this action as defense in any proceeding
initiated by the Commission or any person under the federal
securities laws of the United States.

	In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Investment Management in connection with our review of
your filing or in response to our comments on your filing.
We will consider a written request for acceleration of the
effective
date of the registration statement as a confirmation of the fact
that
those requesting acceleration are aware of their respective
responsibilities.  We will act on the request and, pursuant to
delegated authority, grant acceleration of the effective date.

*    *    *    *    *    *

	Please direct any questions you may have regarding the filing
or
this letter to me at 202.942.0617.

							Sincerely,

							Brion R. Thompson
							Senior Counsel

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