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OppenheimerFunds, Inc.
Two World Financial Center
225 Liberty Street - 11th Floor
New York, New York 10281-1008
January 19, 2007
VIA ELECTRONIC TRANSMISSION
Securities and Exchange Commission
450 Fifth Street, N.W.
Judiciary Plaza
Washington, D.C. 20549
Attention: Division of Investment Management
Re: Oppenheimer Baring Japan Fund
File Nos. 333-137581 and 811-21954
Ladies and Gentlemen:
We have reviewed your comments on the registration statement on Form N-1A
(the "Registration Statement") for the Oppenheimer Baring Japan Fund (the
"Fund"), filed with the Commission on January 16, 2007. We confirm that
OppenheimerFunds, Inc., the Fund's investment manager, has voluntarily agreed to
waive management fees and/or reimburse the Fund for certain expenses so that
"Total Annual Fund Operating Expenses" will not exceed 1.60% for Class A shares
and 2.35% for Class B shares and Class C shares, 1.85% for Class N and 1.35% for
Class Y, respectively. In addition, we have confirmed that "Other Expenses" are
not expected to exceed 0.35%. We have estimated the Fund's transfer agency fees
at approximately 0.25% and the Fund's custody fees are not expected to exceed
0.02%.
We would be pleased to provide you with any additional information you may
require. We would appreciate it if any further comments the Commission Staff may
have on this filing be directed to the undersigned at OppenheimerFunds, Inc.,
Two World Financial Center, 225 Liberty Street, New York, New York 10281, (212)
323-5089.
Very truly yours,
/s/ Nancy S. Vann
Nancy S. Vann
Vice President & Associate Counsel
Enclosures
cc: Vincent DiStefano, Esq.
Phillip S. Gillespie, Esq.