0000919574-10-005392.txt : 20110426
0000919574-10-005392.hdr.sgml : 20110426
20100916090540
ACCESSION NUMBER: 0000919574-10-005392
CONFORMED SUBMISSION TYPE: CORRESP
PUBLIC DOCUMENT COUNT: 1
FILED AS OF DATE: 20100916
FILER:
COMPANY DATA:
COMPANY CONFORMED NAME: ALLIANCEBERNSTEIN VARIABLE PRODUCTS SERIES FUND INC
CENTRAL INDEX KEY: 0000825316
IRS NUMBER: 000000000
FISCAL YEAR END: 1231
FILING VALUES:
FORM TYPE: CORRESP
BUSINESS ADDRESS:
STREET 1: ALLIANCEBERNSTEIN LP
STREET 2: 1345 AVENUE OF THE AMERICAS
CITY: NEW YORK
STATE: NY
ZIP: 10105
BUSINESS PHONE: 2129691000
MAIL ADDRESS:
STREET 1: ALLIANCEBERNSTEIN LP
STREET 2: 1345 AVENUE OF THE AMERICAS
CITY: NEW YORK
STATE: NY
ZIP: 10105
CORRESP
1
filename1.txt
Seward & Kissel LLP
1200 G Street, N.W.
Washington, D.C. 20005
Telephone: (202) 737-8833
Facsimile: (202) 737-5184
www.sewkis.com
September 15, 2010
VIA EDGAR
Division of Investment Management
Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Re: AllianceBernstein Variable Products Series Fund, Inc.
Preliminary Proxy Statement
File Nos. 033-18647 and 811-05398
Dear Mr. Kosoff:
This letter responds to comments of the staff (the "Staff") of the
Securities and Exchange Commission (the "SEC") to the Preliminary Proxy
Statement of AllianceBernstein Variable Products Series Fund, Inc. (the "Fund"),
as provided orally to Kathleen Clarke of this office on September 3, 2010. The
Staff's comments and our responses are discussed below.
Comment 1: Commodities Policy: The Staff believes that the proposed commodities
policy is not definite enough and does not describe the policy
except by reference to the Prospectus and Statement of Additional
Information ("SAI"). The Staff suggested that the policy could, for
example, be changed to state that the Portfolios may invest in
commodities and that the discussion could reference the policies in
the Prospectus and SAI.
Response: We have revised the disclosure in response to this comment.
Comment 2: Proxy Solicitor Disclosure (Page 23). This disclosure needs to
include a brief description of the services provided by the proxy
solicitor (see Item 4(a)(3) of Schedule 14A).
Response: We have revised the disclosure in response to this comment.
Comment 3: Costs of Solicitation. Disclosure of the persons by whom the costs
of solicitation will be borne needs to be added (see Item 4(a)(4) of
Schedule 14A ..
Response: We have revised the disclosure in response to this comment.
* * *
We hereby acknowledge that (i) the Fund is responsible for the adequacy
and accuracy of the disclosures in the filings; (ii) Staff comments or changes
to disclosure in response to Staff comments in the filings reviewed by the Staff
do not foreclose the SEC from taking any action with respect to the filing; and
(iii) the Fund may not assert Staff comments as a defense in any proceedings
initiated by the SEC or any person under the federal securities laws of the
United States.
If you have any additional comments or questions, please contact Kathleen
Clarke or the undersigned at (202) 737-8833.
Sincerely,
/s/ Young Seo
-------------
Young Seo
cc: Nancy Hay, Esq.
Kathleen K. Clarke, Esq.
SK 00250 0451 1129223