CORRESP 1 filename1.htm d1265259_corresp.htm

 
SEWARD & KISSEL LLP
ONE BATTERY PARK PLAZA
NEW YORK, NEW YORK  10004
  
     
 
 
TELEPHONE:  (212)  574-1200
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FACSIMILE:  (202) 737-5184


 
 
February 16, 2012
 
 
VIA EDGAR
Tom Kluck
Branch Chief
Division of Corporation Finance
U.S. Securities and Exchange Commission
100 F Street N.E.
Washington, DC 20549
  

 
 
Re:
Sprott Physical Silver Trust
Form 20-F for the Fiscal Year Ended December 31, 2010
Filed June 27, 2011
File No. 001-34928
 

Dear Mr. Kluck:
 
On behalf of Sprott Physical Silver Trust (the “Trust”), we submit this response to your letter dated December 20, 2011, in which the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) presented a comment relating to the Trust’s annual report on Form 20-F for the fiscal year ended December 31, 2010. The Trust’s response, together with the Staff’s comment, is set forth below.
 
1.
In future Exchange Act filings, please provide disclosure of the total fees and expenses paid by the trust and include an expense ratio for an investment in the trust. Please describe all the components that you have included in the expense ratio and explain any assumptions you have made.
 
The Trust will include the requested disclosure in future Exchange Act filings.
 
________________

 
The Trust acknowledges that: (i) it is responsible for the adequacy and accuracy of the disclosure in the filing; (ii) Staff comments or changes to the disclosure in response to Staff comments do not foreclose the Commission from taking any action with respect to the filing; and (iii) the Trust 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.
 
____________________
 
We trust that the information provided in this letter addresses the Staff’s comments.  If you have any questions or comments concerning this letter, please feel free to contact the undersigned at 202-661-7150.
 
 
Very truly yours,
 
SEWARD & KISSEL, LLP
 
By: /s/ Anthony Tu-Sekine    
      Anthony Tu-Sekine




SK 03883 0009 1265259
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