Subject: File No. S7-28-07
From: Robert F Cardell

February 8, 2008

I have to applaud the commission attempt to distill the essence of a lengthily prospectus into something more user friendly. Having read most of the proceeding comments, I can see that others would also appreciate this action.

A few comments:
I would appreciate having Principal Investment Strategies spell out what specific benchmark the fund would like its results to measured against.
And, I would appreciate it if the Average Annual Total Return would use as a comparison this benchmark, not the S P.