Subject: File Number S7-15-10

October 18, 2010

Whle 12b-1 fees may not be the method of choice, it is a fair maeans of charging the middle calss investors which need the most assistance. To charge a A-share fee is of course cheaper in the long run, but we no longer seem to living in a long term world, seeing the need quite frequently to move investments every year or two.Thus the C-share, 12-b1 fees are much more fair and equitable ot all concerned.

John Russell