CORRESP 44 ltr.htm

(logo) Fidelity Investments®||||||||||||||||||||||||||||||||||||||||||||||||||||||||||

FPCMS
82 Devonshire Street
Boston MA 02109-3614
617-563-7000

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October 22, 2004

Securities and Exchange Commission

Judiciary Plaza

450 Fifth Street, N.W.

Washington, D.C. 20549

Attn: Christian Sandoe

RE:

Fidelity Advisor Series VIII (the trust):

Fidelity Advisor Diversified International Fund
Fidelity Advisor Emerging Asia Fund
Fidelity Advisor Emerging Makets Fund
Fidelity Advisor Europe Capital Appreciation Fund
Fidelity Advisor Global Equity Fund
Fidelity Advisor International Capital Appreciation Fund
Fidelity Advisor Japan Fund
Fidelity Advisor Korea Fund
Fidelity Advisor Latin America Fund
Fidelity Advisor Overseas Fund
Fidelity Advisor Value Leaders Fund (the funds)

File Nos. (002-86711) and (811-03855)

Post-Effective Amendment No. 77

Ladies and Gentlemen:

Pursuant to Rule 8b-16 under the Investment Company Act of 1940, as amended, Regulation S-T and Rule 485(a) under the Securities Act of 1933, as amended, transmitted herewith on behalf of the trust is Post-Effective Amendment No. 77 to the trust's current effective Registration Statement on Form N-1A. This transmission contains a conformed signature page, the manually signed original of which, executed pursuant to Powers of Attorney dated June 14, 2001, and June 1, 2004, is maintained at the offices of the trust. This filing also includes a conformed copy of the manually signed consent of the trust's independent registered public accounting firm, the original of which is maintained at the offices of the trust.

This filing contains the Prospectuses and Statement of Additional Information for Fidelity Advisor Diversified International Fund, Fidelity Advisor Emerging Asia Fund, Fidelity Advisor Emerging Makets Fund, Fidelity Advisor Europe Capital Appreciation Fund, Fidelity Advisor Global Equity Fund, Fidelity Advisor International Capital Appreciation Fund, Fidelity Advisor Japan Fund, Fidelity Advisor Korea Fund, Fidelity Advisor Latin America Fund, Fidelity Advisor Overseas Fund, and Fidelity Advisor Value Leaders Fund. The documents have been tagged to indicate modifications and editorial changes made since the last definitive filing. The funds may be marketed through banks, savings and loan associations, or credit unions.

This filing serves to update certain disclosure, incorporate supplements to the Prospectuses and Statement of Additional Information, and implement certain editorial changes.

Please note that disclosures required as a result of SEC Final Rule: Disclosure Regarding Market Timing and Selective Disclosure of Portfolio Holdings is included in this filing.

Please also note that disclosure required as a result of SEC Final Rule: Disclosure of Breakpoint Discounts by Mutual Funds is included in this filing.

Pursuant to Rule 485(a), the trust elects an effective date of December 30, 2004. We request your comments by November 22, 2004.

Please contact Jill Nareau Robert at (617) 563-0824 in connection with any questions or comments regarding this filing.

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Sincerely,

/s/ Aaron Esker

Aaron Esker

Legal Product Group