Subject: File No. S7-28-07
From: D. G. Birmingham
Affiliation: Systems Engineer

February 13, 2008

After Reading your example the following suggestions come to mind:

1. Under the Portfolio Manager:
If he has been the portfolio manager for less than 5 years, his previous position(s) should be listed going back 10 Years.

2. Payments at the end of your three pages. If the broker or adviser receives a payment from the company an example based on a $10,000 invest should be given, as follows:
For 'A' shares, if you invest $10,000.00 the broker or adviser will be paid a commission of 5% (or $500 dollars) from your account. Your resultant balance on the first day will be $9,500.00. Based on average returns for the last 10 years, it will be xx months to recover the commission and return your balance to your original investment of $10,000.00.


D Birmingham