Subject: File No. S7-15-10
From: Ramachandra Sattigeri, PhD
Affiliation: Research Scientist, Aerospace Engineering

October 22, 2010

I oppose the imposition of 12b-1 fees on the grounds it doesn't help improve the performance of the mutual fund. It certainly is annoying that it is a fixed percentage rather than a fixed amount in absolute terms. It should at least be applied only when the fund in question has a positive performance rate.