VIA EDGAR

Brent Fields, Assistant Director

Office of Disclosure and Review

Division of Investment Management

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

Re:	Fidelity Advisor Biotechnology Fund	Fidelity Government Income Fund
	Fidelity Advisor Communications Equipment Fund	Fidelity Growth & Income Fund
	Fidelity Advisor Consumer Discretionary Fund	Fidelity Intermediate Government Income Fund
	Fidelity Advisor Electronics Fund	Fidelity International Real Estate Fund
	Fidelity Advisor Energy Fund	Fidelity Leveraged Company Stock Fund
	Fidelity Advisor Financial Services Fund	Fidelity Low Priced Stock Fund
	Fidelity Advisor Health Care Fund	Fidelity OTC Portfolio
	Fidelity Advisor Industrials Fund	Fidelity Real Estate Income Fund
	Fidelity Advisor Leveraged Company Stock Fund	Fidelity Real Estate Investment Portfolio
	Fidelity Advisor Real Estate Fund	Fidelity Series Commodity Strategy Fund
	Fidelity Advisor Technology Fund	Fidelity Series Small Cap Opportunities Fund
	Fidelity Advisor Utilities Fund	Fidelity Small Cap Growth Fund
	Fidelity Blue Chip Growth Fund	Fidelity Small Cap Value Fund
	Fidelity Blue Chip Value Fund	Fidelity Strategic Advisers Core Fund
	Fidelity Commodity Strategy Fund	Fidelity Strategic Advisers Value Fund
	Fidelity Dividend Growth Fund	Fidelity Ultra-Short Bond Fund
	Fidelity GNMA Fund (formerly Fidelity Ginnie Mae Fund)	Fidelity Value Discovery Fund
	Request pursuant to Rule 485(b)(1)(vii)

Dear Mr. Fields:

We are currently preparing the annual update filings for Fidelity Advisor Biotechnology Fund, Fidelity Advisor Communications Equipment Fund, Fidelity Advisor Consumer Discretionary Fund, Fidelity Advisor Electronics Fund, Fidelity Advisor Energy Fund, Fidelity Advisor Financial Services Fund, Fidelity Advisor Health Care Fund, Fidelity Advisor Industrials Fund, Fidelity Advisor Leveraged Company Stock Fund, Fidelity Advisor Real Estate Fund, Fidelity Advisor Technology Fund, Fidelity Advisor Utilities Fund, Fidelity Blue Chip Growth Fund, Fidelity Blue Chip Value Fund, Fidelity Commodity Strategy Fund, Fidelity Dividend Growth Fund, Fidelity GNMA Fund (formerly Fidelity Ginnie Mae Fund), Fidelity Government Income Fund, Fidelity Growth & Income Fund, Fidelity Intermediate Government Income Fund, Fidelity International Real Estate Fund, Fidelity Leveraged Company Stock Fund, Fidelity Low Priced Stock Fund, Fidelity OTC Portfolio, Fidelity Real Estate Income Fund, Fidelity Real Estate Investment Portfolio, Fidelity Series Commodity Strategy Fund, Fidelity Series Small Cap Opportunities Fund, Fidelity Small Cap Growth Fund, Fidelity Small Cap Value Fund, Fidelity Strategic Advisers Core Fund, Fidelity Strategic Advisers Value Fund, Fidelity Ultra-Short Bond Fund, and Fidelity Value Discovery Fund (the funds). Because the funds will include disclosure relating to the Enhanced Disclosure and New Prospectus Delivery Option for Registered Open-End Management Investment Companies Final Rule that is substantially the same as disclosure relating to the subject that was included in the 485(a) filings submitted to the Staff on October 16, 2009, November 16, 2009, December 15, 2009, January 15, 2010, and January 25, 2010 (see Attachment 1 for list of trusts/funds), we respectfully request permission to file the annual update filings for the funds under Rule 485(b)(1)(vii). The funds' filings contain other nonmaterial changes, including additional disclosure intended to highlight the disclosure included in the October 16, 2009, November 16, 2009, December 15, 2009, January 15, 2010, and January 25, 2010, 485(a) filings, but contain no other disclosures that would make them ineligible to file under Rule 485(b).

We would appreciate an early response to this request so that we can plan our filing schedule accordingly. Please call me at (617) 563-1375 if you have any questions or comments. Thank you for your consideration.

Identifying information for the funds for which this request is made is provided in Attachment 1.

Sincerely,

/s/ Jamie Plourde

Jamie Plourde

Senior Product Manager I

cc: Christian Sandoe

Attachment 1

Name of Trust and/or Fund(s) for which rule 485(b)(1)(vii) relief is requested:

Similar Trust/Fund(s) in which the new disclosure was previously subject to review:

Fidelity Advisor Series I: Fidelity Advisor Leveraged Company Stock Fund SEC File Numbers/CIK Numbers 811-03785 002-84776 0000722574

Fidelity Advisor Series I: Fidelity Advisor Dividend Growth Fund Fidelity Advisor Equity Growth Fund Fidelity Advisor Equity Value Fund Fidelity Advisor Growth & Income Fund Fidelity Advisor Growth Opportunities Fund Fidelity Advisor Large Cap Fund Fidelity Advisor Strategic Growth Fund Fidelity Advisor Value Fund Fidelity Advisor Value Strategies Fund SEC File Numbers/CIK Numbers 811-03785 002-84776 0000722574 485(a) filing submitted November 16, 2009

Name of Trust and/or Fund(s) for which rule 485(b)(1)(vii) relief is requested:

Similar Trust/Fund(s) in which the new disclosure was previously subject to review:

Fidelity Advisor Series VII: Fidelity Advisor Biotechnology Fund Fidelity Advisor Communications Equipment Fund Fidelity Advisor Consumer Discretionary Fund Fidelity Advisor Electronics Fund Fidelity Advisor Energy Fund Fidelity Advisor Financial Services Fund Fidelity Advisor Health Care Fund Fidelity Advisor Industrials Fund Fidelity Advisor Real Estate Fund Fidelity Advisor Technology Fund Fidelity Advisor Utilities Fund SEC File Numbers/CIK Numbers 811-03010 002-67004 0000315700

Fidelity Advisor Series VIII: Fidelity Advisor Diversified International Fund Fidelity Advisor Emerging Asia Fund Fidelity Advisor Emerging Markets Fund Fidelity Advisor Japan Fund Fidelity Advisor Latin America Fund Fidelity Advisor Overseas Fund Fidelity Advisor Value Leaders Fund SEC File Numbers/CIK Numbers 811-03855 002-86711 0000729218 485(a) filing submitted October 16, 2009

Name of Trust and/or Fund(s) for which rule 485(b)(1)(vii) relief is requested:	Similar Trust/Fund(s) in which the new disclosure was previously subject to review:
Fidelity Commonwealth Trust II: Fidelity Strategic Advisers Value Fund SEC File Numbers/CIK Numbers 811-21990 333-139428 0001364923	Fidelity Rutland Square Trust II: Fidelity Strategic Advisers Growth Fund SEC File Numbers/CIK Numbers 811-21991 333-139427 0001364924 485(a) filing submitted January 25, 2010

Name of Trust and/or Fund(s) for which rule 485(b)(1)(vii) relief is requested:	Similar Trust/Fund(s) in which the new disclosure was previously subject to review:
Fidelity Devonshire Trust: Fidelity Real Estate Investment Portfolio SEC File Numbers/CIK Numbers 811-01352 002-24389 0000035341	Fidelity Devonshire Trust: Fidelity Equity-Income Fund SEC File Numbers/CIK Numbers 811-01352 002-24389 0000035341 485(a) filing submitted January 15, 2010

Name of Trust and/or Fund(s) for which rule 485(b)(1)(vii) relief is requested:	Similar Trust/Fund(s) in which the new disclosure was previously subject to review:
Fidelity Fixed-Income Trust: Fidelity Commodity Strategy Fund Fidelity Series Commodity Strategy Fund SEC File Numbers/CIK Numbers 811-02105 002-41839 0000035315	Fidelity Commonwealth Trust: Fidelity Series 100 Index Fund SEC File Numbers/CIK Numbers 811-02546 002-52322 0000205323 485(a) filing submitted November 16, 2009 ------------------------- Fidelity Investment Trust: Fidelity Global Commodity Stock Fund SEC File Numbers/CIK Numbers 811-04008 002-90649 0000744822 485(a) filing submitted October 16, 2009

Name of Trust and/or Fund(s) for which rule 485(b)(1)(vii) relief is requested:	Similar Trust/Fund(s) in which the new disclosure was previously subject to review:
Fidelity Income Fund: Fidelity GNMA Fund (formerly Fidelity Ginnie Mae Fund) Fidelity Government Income Fund Fidelity Intermediate Government Income Fund Fidelity Ultra-Short Bond Fund SEC File Numbers/CIK Numbers 811-04085 002-92661 0000751199	Fidelity School Street Trust: Fidelity Intermediate Municipal Income Fund Fidelity Strategic Income Fund SEC File Numbers/CIK Numbers 811-02676 002-57167 0000215829 485(a) filing submitted December 15, 2009

Name of Trust and/or Fund(s) for which rule 485(b)(1)(vii) relief is requested:	Similar Trust/Fund(s) in which the new disclosure was previously subject to review:
Fidelity Puritan Trust: Fidelity Low Priced Stock Fund Fidelity Value Discovery Fund SEC File Numbers/CIK Numbers 811-00649 002-11884 0000081205	Fidelity Capital Trust: Fidelity Capital Appreciation Fund Fidelity Disciplined Equity Fund Fidelity Focused Stock Fund Fidelity Small Cap Independence Fund Fidelity Stock Selector Fidelity Value Fund SEC File Numbers/CIK Numbers 811-02841 002-61760 0000275309 485(a) filing submitted October 16, 2009

Name of Trust and/or Fund(s) for which rule 485(b)(1)(vii) relief is requested:	Similar Trust/Fund(s) in which the new disclosure was previously subject to review:
Fidelity Rutland Square Trust II: Fidelity Strategic Advisers Core Fund SEC File Numbers/CIK Numbers 811-21991 333-139427 0001364924	Fidelity Rutland Square Trust II: Fidelity Strategic Advisers Growth Fund SEC File Numbers/CIK Numbers 811-21991 333-139427 0001364924 485(a) filing submitted January 25, 2010

Name of Trust and/or Fund(s) for which rule 485(b)(1)(vii) relief is requested:

Similar Trust/Fund(s) in which the new disclosure was previously subject to review:

Fidelity Securities Fund: Fidelity Blue Chip Growth Fund Fidelity Blue Chip Value Fund Fidelity Dividend Growth Fund Fidelity Growth & Income Fund Fidelity International Real Estate Fund Fidelity Leveraged Company Stock Fund Fidelity OTC Portfolio Fidelity Real Estate Income Fund Fidelity Small Cap Growth Fund Fidelity Small Cap Value Fund Fidelity Series Small Cap Opportunities Fund SEC File Numbers/CIK Numbers 811-04118 002-93601 0000754510

Fidelity Mt. Vernon Street Trust: Fidelity 130/30 Large Cap Fund Fidelity Growth Company Fund Fidelity Growth Strategies Fund Fidelity New Millennium Fund SEC File Numbers/CIK Numbers 811-03583 002-79755 0000707823 485(a) filing submitted November 16, 2009