COMMENTS RECEIVED ON NOVEMBER 19, 2004, NOVEMBER 23, 2004, NOVEMBER 30, 2004, and DECEMBER 6, 2004

FROM CHRISTIAN SANDOE

FIDELITY ADVISOR SERIES II (File Nos. 033-06516 and 811-04707)

Fidelity Advisor Floating Rate High Income Fund, Fidelity Advisor Government Investment Fund, Fidelity Advisor High Income Fund, Fidelity Advisor High Income Advantage Fund, Fidelity Advisor Intermediate Bond Fund, Fidelity Advisor Mortgage Securities Fund, Fidelity Advisor Municipal Income Fund, Fidelity Advisor Short Fixed-Income Fund, and Fidelity Advisor Value Fund

POST-EFFECTIVE AMENDMENT NOS. 70 & 72

FIDELITY ADVISOR SERIES VIII (File Nos. 002-86711 and 811-03855)

Fidelity Advisor Diversified International Fund, Fidelity Advisor Emerging Asia Fund, Fidelity Advisor Emerging Markets Fund, Fidelity Advisor Europe Capital Appreciation Fund, Fidelity Advisor Global Equity Fund, Fidelity Advisor International Capital Appreciation Fund, Fidelity Advisor Japan Fund, Fidelity Advisor Korea Fund, Fidelity Advisor Latin America Fund, Fidelity Advisor Overseas Fund, and Fidelity Advisor Value Leaders Fund

POST-EFFECTIVE AMENDMENT NO. 77

FIDELITY BEACON STREET TRUST (File Nos. 002-64791 and 811-02933)

Fidelity Advisor Tax Managed Stock Fund and Fidelity Tax Managed Stock Fund

POST-EFFECTIVE AMENDMENT NO. 56

FIDELITY CAPITAL TRUST (File Nos. 002-61760 and 811-02841)

Fidelity Capital Appreciation Fund, Fidelity Disciplined Equity Fund, Fidelity Focused Stock Fund, Fidelity Small Cap Independence Fund, Fidelity Stock Selector Fund, and Fidelity Value Fund

POST-EFFECTIVE AMENDMENT NO. 85

FIDELITY INVESTMENT TRUST (File Nos. 002-90649 and 811-04008)

Fidelity Aggressive International Fund, Fidelity Canada Fund, Fidelity China Region Fund, Fidelity Diversified International Fund, Fidelity Emerging Markets Fund, Fidelity Europe Capital Appreciation Fund, Fidelity Europe Fund, Fidelity Global Balanced Fund, Fidelity International Discovery Fund, Fidelity International Small Cap Fund, Fidelity Japan Fund, Fidelity Japan Smaller Companies Fund, Fidelity Latin America Fund, Fidelity Nordic Fund, Fidelity Overseas Fund, Fidelity Pacific Basin Fund, Fidelity Southeast Asia Fund, and Fidelity Worldwide Fund

POST-EFFECTIVE AMENDMENT NO. 89

NEWBURY STREET TRUST (File Nos. 002-78458 and 811-03518)

Treasury Fund, Prime Fund, and Tax-Exempt Fund

POST-EFFECTIVE AMENDMENT NO. 45

1. All funds (except Treasury Fund, Prime Fund, and Tax-Exempt Fund)

"Buying and Selling Shares" (prospectuses)

"The fund's excessive trade monitoring policy described above does not apply to transactions initiated by the trustee or adviser to a donor-advised charitable gift fund, qualified fund-of-funds or other strategy funds, or omnibus accounts. Trustees or advisers of donor-advised charitable gift funds must certify that they either work from an asset allocation model or direct transactions in the donor accounts in concert with changes in a model portfolio and that donors are limited in their ability to influence investments by the trust. A qualified fund-of-fund is a mutual fund or other strategy fund consisting of qualified plan assets that either applies the fund's policies on frequent trading to shareholders at the top-fund level, or demonstrates that it has policies designed to control frequent trading and that they are reasonably likely to be effective as determined by the fund's Treasurer. The adviser to the top-fund level must also demonstrate to the fund's Treasurer that its investment strategy will not lead to excessive trading. Strategy funds must commence monitoring for excessive trading no later than March 31, 2005. Omnibus accounts are maintained by intermediaries acting on behalf of multiple investors whose individual trades are not ordinarily disclosed to the fund. Short-term trading by these investors is almost certain to go undetected by the fund and may increase costs and disrupt portfolio management. The fund will monitor aggregate trading in qualified fund-of-funds and known omnibus accounts to attempt to identify disruptive trades, focusing on transactions in excess of $250,000. There is no assurance that these policies will be effective, or will successfully detect or deter market timing."

Fidelity Advisor Series II (File Nos. 033-06516 and 811-04707), Post-Effective Amendment Nos. 70 & 72; Fidelity Advisor Series VIII (File Nos. 002-86711 and 811-03855), Post-Effective Amendment No. 77; Fidelity Beacon Street Trust (File Nos. 002-64791 and 811-02933), Post Effective Amendment No. 56; Fidelity Capital Trust (File Nos. 002-61760 and 811-02841), Post Effective Amendment No. 85; Fidelity Investment Trust (File Nos. 002-90649 and 811-04008) Post Effective Amendment No. 89; Newbury Street Trust (File Nos. 002-78458 and 811-03518), Post Effective Amendment No. 89

C: The Staff would like an explanation of how the funds will monitor aggregate trading in excess of $250,000 and the steps taken if market timing is detected in a known omnibus account.

R: Our practice is to review trades in excess of $250,000 in an attempt to identify short-term trading that may be disruptive to portfolio management. If detected, we will contact the omnibus account holders and ask them to explain who the underlying investors are, and what their intentions are. We urge omnibus account holders to impede potentially disruptive trading activity at their level. If the omnibus account holder's explanation fails to reassure FMR that the account holder's subsequent trading is not likely to be disruptive, FMR may prevent further exchanges by electronic means, requiring mailing of exchange transactions.

2. Treasury Fund, Prime Fund, and Tax-Exempt Fund

"Buying and Selling Shares" (prospectuses)

"Frequent purchases and sales of fund shares can harm shareholders in various ways, including reducing the returns to long-term shareholders by increasing costs to the fund (such as spreads paid to dealers who sell money market instruments to the fund) and disrupting portfolio management strategies. Accordingly, the Board of Trustees has adopted policies and procedures designed to discourage excessive or short-term trading of fund shares. As money market funds, each fund is designed to offer investors a liquid cash option and FMR anticipates that shareholders will purchase and sell fund shares frequently.

Each fund has no limit on purchase or exchange transactions. Accordingly, the Board of Trustees has not adopted policies and procedures designed to discourage excessive or short-term trading of fund shares and each fund accommodates frequent trading. Each fund reserves the right, but does not have the obligation, to reject any purchase or exchange transaction at any time. In addition, FMR reserves the right to impose restrictions on purchases or exchanges at any time on conditions that are more restrictive on disruptive, excessive, or short-term trading than those that are otherwise stated in this prospectus."

C: The Staff believes that the two underlined sentences above are inconsistent.

R: We will modify the disclosure in the next filing as follows (underlined added; [bracketed] deleted):

"Frequent purchases and sales of fund shares can harm shareholders in various ways, including reducing the returns to long-term shareholders by increasing costs to the fund (such as spreads paid to dealers who sell money market instruments to a fund) and disrupting portfolio management strategies. However, FMR anticipates that shareholders will purchase and sell fund shares frequently because each fund is designed to offer investors a liquid cash option. Accordingly, the Board of Trustees has not adopted policies and procedures designed to discourage excessive or short-term trading of fund shares and each fund accommodates frequent trading. [As money market funds, each fund is designed to offer investors a liquid cash option and FMR anticipates that shareholders will purchase and sell fund shares frequently.]

Each fund has no limit on purchase or exchange transactions. [Accordingly, the Board of Trustees has not adopted policies and procedures designed to discourage excessive or short-term trading of fund shares and each fund accommodates frequent trading.] Each fund reserves the right, but does not have the obligation, to reject any purchase or exchange transaction at any time. In addition, FMR reserves the right to impose restrictions on purchases or exchanges at any time on conditions that are more restrictive on disruptive, excessive, or short-term trading than those that are otherwise stated in this prospectus.''

3. All funds (except Treasury Fund, Prime Fund, and Tax-Exempt Fund)

"Buying and Selling Shares" (prospectuses)

"The fund's Treasurer is authorized to suspend the fund's policies during periods of severe market turbulence or national emergency and to grant exemptions from the policy."

C: The Staff requests specifics on when the policies will not be imposed and whether there are specific people that the fund accommodates market timing for pursuant to Item 6(e)(4)(iii) of Form N-1A. In addition the Staff requests that the fund state in its disclosure whether or not it accommodates market timing pursuant to Item 6(e)(4)(ii) of Form N-1A.

R: The fund will not accept more than two 30 day roundtrips within any 90 day period, except as otherwise provided for the specified account types: omnibus, fund-of-fund, and qualified wrap programs. We will add the following disclosure:

"The fund does not knowingly accommodate purchases and redemptions of fund shares in excess of the polices set out in this prospectus."

4. All funds (except Treasury Fund, Prime Fund, and Tax-Exempt Fund)

"Buying and Selling Shares" (prospectuses)

"Qualified wrap programs will be monitored by matching the adviser's orders for purchase, exchange, or sale transactions in fund shares to determine if the adviser's orders comply with the fund's frequent trading policies. Excessive trading by an adviser will lead to fund blocks and the wrap program will cease to be a qualified wrap program. [Additions to and withdrawals from a qualified wrap program by the adviser's client will not be matched with transactions initiated by the adviser, but client initiated transactions are subject to the fund's policies on frequent trading and individual clients may be subject to restrictions due to their frequent trading in a wrap account.] Commencing no later than March 31, 2005, wrap account client purchases and sale transactions will be monitored under the fund's monitoring policy as though the wrap clients were fund shareholders. A qualified wrap program is: i) a program whose adviser certifies that it has investment discretion over $100 million or more in client assets invested in mutual funds at the time of the certification, ii) a program in which the adviser directs transactions in the accounts participating in the program in concert with changes in a model portfolio, and iii) managed by an adviser who agrees to give FMR sufficient information to permit FMR to identify the individual accounts in the wrap program."

C: The Staff asks: a) Is it "may" or "will" be subject to restrictions?; b) What are the restrictions? and; c) What does the first clause of the underlined text mean?

R: a) We will modify the disclosure to change "may" to "will"; b) A client who buys and then sells shares of a fund within 30 days two or more times within any 90 day period will be blocked from making additional purchases or exchanges of the fund for 85 days, and; c) A roundtrip transaction occurs when a shareholder buys and then sells shares of a fund within 30 days. However, if the adviser buys shares of a fund and an individual client subsequently sells shares of the same fund within 30 days, the client's transaction is not matched with the adviser's and therefore does not count as a roundtrip.

5. Fidelity Advisor Diversified International Fund, Fidelity Advisor Europe Capital Appreciation Fund, Fidelity Advisor Global Equity Fund, Fidelity Advisor International Capital Appreciation Fund, Fidelity Advisor Overseas Fund, Fidelity Aggressive International Fund, Fidelity Diversified International Fund, Fidelity Europe Capital Appreciation Fund, Fidelity Europe Fund, Fidelity Focused Stock Fund, Fidelity Global Balanced Fund, Fidelity International Discovery Fund, Fidelity Overseas Fund, and Fidelity Worldwide Fund

"Buying and Selling Shares" (prospectuses)

"Selling Shares"

(Fidelity Advisor Diversified International Fund, Fidelity Advisor Europe Capital Appreciation Fund, Fidelity Advisor Global Equity Fund, Fidelity Advisor International Capital Appreciation Fund, and Fidelity Advisor Overseas Fund)

"The fund will deduct a 1.00% short-term trading fee from the redemption amount if you sell your shares or your shares are redeemed for failure to maintain the account minimum after holding them less than 30 days. For this purpose, shares held longest will be treated as being redeemed first and shares held shortest as being redeemed last. The short-term trading fee does not apply to shares that were acquired through reinvestment of distributions."

(Fidelity Europe Fund and Fidelity Europe Capital Appreciation Fund)

"Canada, China Region, Emerging Markets, Japan, Japan Smaller Companies, Latin America, Nordic, Pacific Basin, and Southeast Asia will deduct a 1.50% short-term trading fee from the redemption amount if you sell your shares or your shares are redeemed for failure to maintain the balance minimum after holding them less than 90 days. Europe and Europe Capital Appreciation will deduct a 1.00% short-term trading fee from the redemption amount if you sell your shares or your shares are redeemed for failure to maintain the balance minimum after holding them less than 30 days. For this purpose, shares held longest will be treated as being redeemed first and shares held shortest as being redeemed last. The short-term trading fee does not apply to shares that were acquired through reinvestment of distributions. If you sell shares through a retirement account you may or may not pay a short-term trading fee."

(Fidelity Aggressive International Fund, Fidelity Diversified International Fund, Fidelity Global Balanced Fund, Fidelity Overseas Fund, and Fidelity Worldwide Fund)

"Each fund will deduct a 1.00% short-term trading fee from the redemption amount if you sell your shares or your shares are redeemed for failure to maintain the balance minimum after holding them less than 30 days. For this purpose, shares held longest will be treated as being redeemed first and shares held shortest as being redeemed last. The short-term trading fee does not apply to shares that were acquired through reinvestment of distributions. If you sell shares through a retirement account you may or may not pay a short-term trading fee."

(Fidelity International Discovery Fund)

"The fund will deduct a 1.00% short-term trading fee from the redemption amount if you sell your shares or your shares are redeemed for failure to maintain the balance minimum after holding them less than 30 days. For this purpose, shares held longest will be treated as being redeemed first and shares held shortest as being redeemed last. The short-term trading fee does not apply to shares that were acquired through reinvestment of distributions. If you sell shares through a retirement account you may or may not pay a short-term trading fee."

(Fidelity Focused Stock Fund)

"Focused Stock will deduct a 0.75% short-term trading fee from the redemption amount if you sell your shares or your shares are redeemed for failure to maintain the balance minimum after holding them less than 30 days. For this purpose, shares held longest will be treated as being redeemed first and shares held shortest as being redeemed last. The short-term trading fee does not apply to shares that were acquired through reinvestment of distributions. If you sell shares through a retirement account you may or may not pay a short-term trading fees."

C: The Staff notes that the underlined statement is irrelevant in light of the Scudder no-action letter. The policy would never be applicable on forced redemptions because 30 days notice is always required before a forced redemption.

R: We believe that the policy could be applicable under certain fact patterns (i.e., where the shareholder makes a token investment after receiving notice but the token investment is not enough to bring the account to the minimum balance). In addition, we are not relying on the Scudder no-action letter.

6. All funds

"Fund Holdings Information" (SAIs)

C: The Staff noted that there was no disclosure regarding the policies and procedures with respect to the receipt of compensation from making any selective holdings disclosures as required by Item 11(f)(1)(iv) of Form N-1A.

R: Item 11(f)(1)(iv) of Form N-1A calls for us to disclose all those policies and procedures having to do with the receipt of compensation in exchange for disclosing holdings information. We do not receive compensation for that purpose, so we have no policies or procedures to disclose.

7. All funds

"Fund Holdings Information" (SAIs)

"4. Full holdings as of the end of the calendar quarter to firms that, i) calculate information derived from holdings either for use by FMR or by firms that supply their analyses of holdings (but not the holdings themselves) to their clients (including sponsors of retirement plans or their consultants), and ii) enter into agreements that specify that holdings will be kept confidential, that no employee shall trade on the basis of such information, and in which the firms certify their information security policies and procedures, and which limit the nature and type of information that may be disclosed to third parties; and . . .

The entities that may receive the information described in (4) above are: Factset (full holdings daily); iMoneynet (full holdings weekly, one day after the end of the week); Kynex (full holdings weekly); and Vestek (full holdings, as of the end of the calendar quarter, 15 days after the calendar quarter-end)."

C: The staff stated that there seems to be an internal inconsistency in the language. The language in #4 discloses that full holdings are provided as of the end of the calendar quarter but subsequent disclosure states that 3 of the entities receive holdings more frequently.

R: We will modify the disclosure as follows (underlined added; [bracketed] deleted):

"4. The fund will provide [Full] material non-public holdings information [as of the end of the calendar quarter] to [firms] third-parties that, i) calculate information derived from holdings either for use by FMR or by firms that supply their analyses of holdings (but not the holdings themselves) to their clients (including sponsors of retirement plans or their consultants), and ii) enter into agreements that specify that (a) holdings information will be kept confidential, (b) that no employee shall [trade on the basis of such] use the information for their personal benefit, [and] (c) in which the firms certify their information security policies and procedures, and (d) which limit the nature and type of information that may be disclosed to third parties.[; and] . . .

The entities that may receive the information described in (4) above are: Factset (full holdings daily); iMoneynet ([full] aggregate holdings weekly, one day after the end of the week); Kynex (full holdings weekly); [and] Vestek (full holdings, as of the end of the calendar quarter, 15 days after the calendar quarter-end); S&P (full holdings weekly, six days after the end of the week); and Moody's Investor Services (full holdings weekly, six days after the end of the week)."

8. All funds

"Fund Holdings Information" (SAIs)

"As authorized by the Board of Trustees, FMR's Information Policy Committee, acting under the supervision of the FMR Co. Information Security Officer, has established and administers guidelines found to be in the best interest of shareholders concerning the dissemination of fund holdings information, and resolution of conflicts of interest in connection with such disclosure, if any. The Information Policy Committee will, from time to time, report to the Board of Trustees updates to the guidelines and other information related to the disclosure of fund holdings information."

C: The Staff noted that there was no disclosure regarding who at the adviser or fund is authorized to make disclosures of fund holdings or authorized to let others make disclosures as required by Item 11(f)(1)(v) of Form N-1A.

R: We will modify the disclosure as follows to address comments number 8, number 9, and number 10 (underlined added; [bracketed] deleted):

"As authorized by the Board of Trustees, FMR's [Information] Disclosure Policy Committee, [acting under the supervision of the FMR Security Officer,] has established and administers guidelines found by the Board to be in the best interests of shareholders concerning the dissemination of fund holdings information, and resolution of conflicts of interest in connection with such disclosure, if any. The Disclosure Policy Committee reviews and decides on each information request and, if granted, how and by whom that information will be disseminated. The [Information] Disclosure Policy Committee [will, from time to time, report] reports to the Board of Trustees periodically. Any modifications [updates] to the guidelines require prior Board approval [and other information related to the disclosure of fund holdings information].''

9. All funds

"Fund Holdings Information" (SAIs)

"As authorized by the Board of Trustees, FMR's Information Policy Committee, acting under the supervision of the FMR Co. Information Security Officer, has established and administers guidelines found to be in the best interest of shareholders concerning the dissemination of fund holdings information, and resolution of conflicts of interest in connection with such disclosure, if any. The Information Policy Committee will, from time to time, report to the Board of Trustees updates to the guidelines and other information related to the disclosure of fund holdings information."

C: The Staff stated that the disclosure does not actually state what the procedures are for ensuring that disclosure of holdings is in the best interest of shareholders pursuant to Item 11(f)(1)(vi) of Form N-1A.

R: We will modify the disclosure as follows to address comments number 8, number 9, and number 10 (underlined added; [bracketed] deleted):

"As authorized by the Board of Trustees, FMR's [Information] Disclosure Policy Committee, [acting under the supervision of the FMR Security Officer,] has established and administers guidelines found by the Board to be in the best interests of shareholders concerning the dissemination of fund holdings information, and resolution of conflicts of interest in connection with such disclosure, if any. The Disclosure Policy Committee reviews and decides on each information request and, if granted, how and by whom that information will be disseminated. The [Information] Disclosure Policy Committee [will, from time to time, report] reports to the Board of Trustees periodically. Any modifications [updates] to the guidelines require prior Board approval [and other information related to the disclosure of fund holdings information].''

10. All funds

"Fund Holdings Information" (SAIs)

"As authorized by the Board of Trustees, FMR's Information Policy Committee, acting under the supervision of the FMR Co. Information Security Officer, has established and administers guidelines found to be in the best interest of shareholders concerning the dissemination of fund holdings information, and resolution of conflicts of interest in connection with such disclosure, if any. The Information Policy Committee will, from time to time, report to the Board of Trustees updates to the guidelines and other information related to the disclosure of fund holdings information."

C: The Staff stated that the disclosure does not describe the manner in which the Board of Trustees exercises oversight of disclosure of the funds' securities pursuant to Item 11(f)(1)(vii) of Form N-1A.

R: We will modify the disclosure as follows to address comments number 8, number 9, and number 10 (underlined added; [bracketed] deleted):

"As authorized by the Board of Trustees, FMR's [Information] Disclosure Policy Committee, [acting under the supervision of the FMR Security Officer,] has established and administers guidelines found by the Board to be in the best interests of shareholders concerning the dissemination of fund holdings information, and resolution of conflicts of interest in connection with such disclosure, if any. The Disclosure Policy Committee reviews and decides on each information request and, if granted, how and by whom that information will be disseminated. The [Information] Disclosure Policy Committee [will, from time to time, report] reports to the Board of Trustees periodically. Any modifications [updates] to the guidelines require prior Board approval [and other information related to the disclosure of fund holdings information].''

11. Tandy (prospectuses and SAIs)

C: The Staff would like us to affirm the following three statements:

1) The fund is responsible for the adequacy and accuracy of the disclosure in the filings.

2) Staff comments or changes to disclosure in response to Staff comments in the filings reviewed by the Staff do not foreclose the Commission from taking any action with respect to the filing.

3) The fund may not assert Staff comments as a defense in any proceeding initiated by the Commission or any other person under the Federal Securities Laws.

R: We affirm the aforementioned statements.

FOLLOW-UP COMMENTS RECEIVED ON DECEMBER 15, 2004

FROM CHRISTIAN SANDOE

FIDELITY ADVISOR SERIES II (File Nos. 033-06516 and 811-04707)

Fidelity Advisor Floating Rate High Income Fund, Fidelity Advisor Government Investment Fund, Fidelity Advisor High Income Fund, Fidelity Advisor High Income Advantage Fund, Fidelity Advisor Intermediate Bond Fund, Fidelity Advisor Mortgage Securities Fund, Fidelity Advisor Municipal Income Fund, Fidelity Advisor Short Fixed-Income Fund, and Fidelity Advisor Value Fund

POST-EFFECTIVE AMENDMENT NOS. 70 & 72

FIDELITY ADVISOR SERIES VIII (File Nos. 002-86711 and 811-03855)

Fidelity Advisor Diversified International Fund, Fidelity Advisor Emerging Asia Fund, Fidelity Advisor Emerging Markets Fund, Fidelity Advisor Europe Capital Appreciation Fund, Fidelity Advisor Global Equity Fund, Fidelity Advisor International Capital Appreciation Fund, Fidelity Advisor Japan Fund, Fidelity Advisor Korea Fund, Fidelity Advisor Latin America Fund, Fidelity Advisor Overseas Fund, and Fidelity Advisor Value Leaders Fund

POST-EFFECTIVE AMENDMENT NO. 77

FIDELITY BEACON STREET TRUST (File Nos. 002-64791 and 811-02933)

Fidelity Advisor Tax Managed Stock Fund and Fidelity Tax Managed Stock Fund

POST-EFFECTIVE AMENDMENT NO. 56

FIDELITY CAPITAL TRUST (File Nos. 002-61760 and 811-02841)

Fidelity Capital Appreciation Fund, Fidelity Disciplined Equity Fund, Fidelity Focused Stock Fund, Fidelity Small Cap Independence Fund, Fidelity Stock Selector Fund, and Fidelity Value Fund

POST-EFFECTIVE AMENDMENT NO. 85

FIDELITY INVESTMENT TRUST (File Nos. 002-90649 and 811-04008)

Fidelity Aggressive International Fund, Fidelity Canada Fund, Fidelity China Region Fund, Fidelity Diversified International Fund, Fidelity Emerging Markets Fund, Fidelity Europe Capital Appreciation Fund, Fidelity Europe Fund, Fidelity Global Balanced Fund, Fidelity International Discovery Fund, Fidelity International Small Cap Fund, Fidelity Japan Fund, Fidelity Japan Smaller Companies Fund, Fidelity Latin America Fund, Fidelity Nordic Fund, Fidelity Overseas Fund, Fidelity Pacific Basin Fund, Fidelity Southeast Asia Fund, and Fidelity Worldwide Fund

POST-EFFECTIVE AMENDMENT NO. 89

NEWBURY STREET TRUST (File Nos. 002-78458 and 811-03518)

Treasury Fund, Prime Fund, and Tax-Exempt Fund

3. All funds (except Treasury Fund, Prime Fund, and Tax-Exempt Fund)

"Buying and Selling Shares" (prospectuses)

"The fund's Treasurer is authorized to suspend the fund's policies during periods of severe market turbulence or national emergency and to grant exemptions from the policy."

C: The Staff would like confirmation that exemptions to the fund's policies will not be granted to market timers. The Staff would like to know the circumstances where exemptions to the policies would be granted and, if exemptions are granted, additional disclosure. In addition, the Staff thinks that the following statements are inconsistent:

"The fund's Treasurer is authorized to suspend the fund's policies during periods of severe market turbulence or national emergency and to grant exemptions from the policy."

"The fund does not knowingly accommodate purchases and redemptions of fund shares in excess of the polices set out in this prospectus."

R: FMR will not grant exemptions to market timers. We have policies and procedures that were approved by the Board of Trustees and are fairly disclosed in the prospectus as filed. Additionally, we believe the risks associated with these policies are adequately disclosed. We can confirm that the Staff's concern will be referred to the Board of Trustees. However, to address the Staff's concerns we will modify our disclosure as follows ([bracketed] deleted):

"[The fund does not knowingly accommodate purchases and redemptions of fund shares in excess of the polices set out in this prospectus.]"

4. All funds (except Treasury Fund, Prime Fund, and Tax-Exempt Fund)

"Buying and Selling Shares" (prospectuses)

"Qualified wrap programs will be monitored by matching the adviser's orders for purchase, exchange, or sale transactions in fund shares to determine if the adviser's orders comply with the fund's frequent trading policies. Excessive trading by an adviser will lead to fund blocks and the wrap program will cease to be a qualified wrap program. [Additions to and withdrawals from a qualified wrap program by the adviser's client will not be matched with transactions initiated by the adviser, but client initiated transactions are subject to the fund's policies on frequent trading and individual clients may be subject to restrictions due to their frequent trading in a wrap account.] Commencing no later than March 31, 2005, wrap account client purchases and sale transactions will be monitored under the fund's monitoring policy as though the wrap clients were fund shareholders. A qualified wrap program is: i) a program whose adviser certifies that it has investment discretion over $100 million or more in client assets invested in mutual funds at the time of the certification, ii) a program in which the adviser directs transactions in the accounts participating in the program in concert with changes in a model portfolio, and iii) managed by an adviser who agrees to give FMR sufficient information to permit FMR to identify the individual accounts in the wrap program."

C: The Staff requests that we add clarifying language to the underlined text.

R: To address the Staff's concern we will modify the disclosure as follows (underlined added; [bracketed] deleted):

"Additions to and withdrawals from a qualified wrap program by the adviser's client will not be matched with transactions initiated by the adviser[, but]. Therefore if the adviser buys shares of a fund and an individual client subsequently sells shares of the same fund within 30 days, the client's transaction is not matched with the adviser's and therefore does not count as a roundtrip. However, client initiated transactions are subject to the fund's policies on frequent trading and individual clients [may] will be subject to restrictions due to their frequent trading in a wrap account."

5. Fidelity Advisor Diversified International Fund, Fidelity Advisor Europe Capital Appreciation Fund, Fidelity Advisor Global Equity Fund, Fidelity Advisor International Capital Appreciation Fund, Fidelity Advisor Overseas Fund, Fidelity Aggressive International Fund, Fidelity Diversified International Fund, Fidelity Europe Capital Appreciation Fund, Fidelity Europe Fund, Fidelity Focused Stock Fund, Fidelity Global Balanced Fund, Fidelity International Discovery Fund, Fidelity Overseas Fund, and Fidelity Worldwide Fund

"Buying and Selling Shares" (prospectuses)

"Selling Shares"

(Fidelity Advisor Diversified International Fund, Fidelity Advisor Europe Capital Appreciation Fund, Fidelity Advisor Global Equity Fund, Fidelity Advisor International Capital Appreciation Fund, and Fidelity Advisor Overseas Fund)

"The fund will deduct a 1.00% short-term trading fee from the redemption amount if you sell your shares or your shares are redeemed for failure to maintain the account minimum after holding them less than 30 days. For this purpose, shares held longest will be treated as being redeemed first and shares held shortest as being redeemed last. The short-term trading fee does not apply to shares that were acquired through reinvestment of distributions."

(Fidelity Europe Fund and Fidelity Europe Capital Appreciation Fund)

"Canada, China Region, Emerging Markets, Japan, Japan Smaller Companies, Latin America, Nordic, Pacific Basin, and Southeast Asia will deduct a 1.50% short-term trading fee from the redemption amount if you sell your shares or your shares are redeemed for failure to maintain the balance minimum after holding them less than 90 days. Europe and Europe Capital Appreciation will deduct a 1.00% short-term trading fee from the redemption amount if you sell your shares or your shares are redeemed for failure to maintain the balance minimum after holding them less than 30 days. For this purpose, shares held longest will be treated as being redeemed first and shares held shortest as being redeemed last. The short-term trading fee does not apply to shares that were acquired through reinvestment of distributions. If you sell shares through a retirement account you may or may not pay a short-term trading fee."

(Fidelity Aggressive International Fund, Fidelity Diversified International Fund, Fidelity Global Balanced Fund, Fidelity Overseas Fund, and Fidelity Worldwide Fund)

"Each fund will deduct a 1.00% short-term trading fee from the redemption amount if you sell your shares or your shares are redeemed for failure to maintain the balance minimum after holding them less than 30 days. For this purpose, shares held longest will be treated as being redeemed first and shares held shortest as being redeemed last. The short-term trading fee does not apply to shares that were acquired through reinvestment of distributions. If you sell shares through a retirement account you may or may not pay a short-term trading fee."

(Fidelity International Discovery Fund)

"The fund will deduct a 1.00% short-term trading fee from the redemption amount if you sell your shares or your shares are redeemed for failure to maintain the balance minimum after holding them less than 30 days. For this purpose, shares held longest will be treated as being redeemed first and shares held shortest as being redeemed last. The short-term trading fee does not apply to shares that were acquired through reinvestment of distributions. If you sell shares through a retirement account you may or may not pay a short-term trading fee."

(Fidelity Focused Stock Fund)

"Focused Stock will deduct a 0.75% short-term trading fee from the redemption amount if you sell your shares or your shares are redeemed for failure to maintain the balance minimum after holding them less than 30 days. For this purpose, shares held longest will be treated as being redeemed first and shares held shortest as being redeemed last. The short-term trading fee does not apply to shares that were acquired through reinvestment of distributions. If you sell shares through a retirement account you may or may not pay a short-term trading fees."

C: The Staff would like to know what authority we are relying on to force a redemption without 30 days notice.

R: As disclosed in the "Account Features and Polices" or "Features and Polices" section of the prospectus, we have a policy to give 30 days' notice to reestablish the minimum balance if a shareholder's fund or account balance falls below the minimum. In that situation, an investor can make investments during the 30-day notice period but still fail to meet the minimum balance at the expiration of that period. In that case, all shares would be redeemed and the shares that were purchased during the period would be subject to the short-term trading fee.

6. All funds

"Fund Holdings Information" (SAIs)

C: The Staff indicated that whether or not we receive compensation is a policy and it should be disclosed.

R: To address the Staff's concerns we will add the following disclosure:

"FMR has no intention of entering into any arrangements with third parties from which it would derive any monetary benefit for the disclosure of material non-public holdings information. Were it to do so, FMR would seek prior Board approval and disclose such arrangements in the SAI."

12. All funds

"Fund Holdings Information" (SAIs)

C: The Staff asks whether we have any procedures to monitor the use of information pursuant to Item 11(f)(ii) of Form N-1A.

R: The Disclosure Policy Committee has dedicated personnel to oversee the on-going arrangements where information pursuant to Item 11(f)(ii) of Form N-1A is provided to third parties, but there are no specific procedures relating to this particular aspect of their duty.

FOLLOW-UP COMMENTS RECEIVED ON DECEMBER 16, 2004

FROM CHRISTIAN SANDOE

FIDELITY ADVISOR SERIES II (File Nos. 033-06516 and 811-04707)

Fidelity Advisor Floating Rate High Income Fund, Fidelity Advisor Government Investment Fund, Fidelity Advisor High Income Fund, Fidelity Advisor High Income Advantage Fund, Fidelity Advisor Intermediate Bond Fund, Fidelity Advisor Mortgage Securities Fund, Fidelity Advisor Municipal Income Fund, Fidelity Advisor Short Fixed-Income Fund, and Fidelity Advisor Value Fund

POST-EFFECTIVE AMENDMENT NOS. 70 & 72

FIDELITY ADVISOR SERIES VIII (File Nos. 002-86711 and 811-03855)

Fidelity Advisor Diversified International Fund, Fidelity Advisor Emerging Asia Fund, Fidelity Advisor Emerging Markets Fund, Fidelity Advisor Europe Capital Appreciation Fund, Fidelity Advisor Global Equity Fund, Fidelity Advisor International Capital Appreciation Fund, Fidelity Advisor Japan Fund, Fidelity Advisor Korea Fund, Fidelity Advisor Latin America Fund, Fidelity Advisor Overseas Fund, and Fidelity Advisor Value Leaders Fund

POST-EFFECTIVE AMENDMENT NO. 77

FIDELITY BEACON STREET TRUST (File Nos. 002-64791 and 811-02933)

Fidelity Advisor Tax Managed Stock Fund and Fidelity Tax Managed Stock Fund

POST-EFFECTIVE AMENDMENT NO. 56

FIDELITY CAPITAL TRUST (File Nos. 002-61760 and 811-02841)

Fidelity Capital Appreciation Fund, Fidelity Disciplined Equity Fund, Fidelity Focused Stock Fund, Fidelity Small Cap Independence Fund, Fidelity Stock Selector Fund, and Fidelity Value Fund

POST-EFFECTIVE AMENDMENT NO. 85

FIDELITY INVESTMENT TRUST (File Nos. 002-90649 and 811-04008)

Fidelity Aggressive International Fund, Fidelity Canada Fund, Fidelity China Region Fund, Fidelity Diversified International Fund, Fidelity Emerging Markets Fund, Fidelity Europe Capital Appreciation Fund, Fidelity Europe Fund, Fidelity Global Balanced Fund, Fidelity International Discovery Fund, Fidelity International Small Cap Fund, Fidelity Japan Fund, Fidelity Japan Smaller Companies Fund, Fidelity Latin America Fund, Fidelity Nordic Fund, Fidelity Overseas Fund, Fidelity Pacific Basin Fund, Fidelity Southeast Asia Fund, and Fidelity Worldwide Fund

POST-EFFECTIVE AMENDMENT NO. 89

NEWBURY STREET TRUST (File Nos. 002-78458 and 811-03518)

Treasury Fund, Prime Fund, and Tax-Exempt Fund

POST-EFFECTIVE AMENDMENT NO. 45

3. All funds (except Treasury Fund, Prime Fund, and Tax-Exempt Fund)

"Buying and Selling Shares" (prospectuses)

"The fund's Treasurer is authorized to suspend the fund's policies during periods of severe market turbulence or national emergency and to grant exemptions from the policy."

C: The Staff would like us to retain the following disclosure, which we have proposed to delete, and make it consistent with the disclosure above.

"The fund does not knowingly accommodate purchases and redemptions of fund shares in excess of the polices set out in this prospectus."

R: To address the Staff's concerns, we will modify our disclosure as follows (underlined added; [bracketed] deleted):

"The fund does not knowingly accommodate frequent purchases and redemptions of fund shares [in excess of the polices set out in this prospectus] by investors, except as provided under the fund's policies with respect to known omnibus accounts, qualified fund-of-funds, qualified wrap accounts, donor-advised charitable gift funds, and 30 day roundtrips."

6. All funds

"Fund Holdings Information" (SAIs)

C: The Staff reiterated that whether or not we receive compensation is a policy and it should be disclosed.

R: To address the Staff's concerns we will replace the disclosure we proposed to add with the following:

"FMR will not enter into any arrangements with third parties from which it would derive any monetary benefit for the disclosure of material non-public holdings information. If, in the future, FMR desired to make such an arrangement, it would seek prior Board approval and any such arrangements would be disclosed in the fund's SAI."