Re:
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Post-Effective Amendment No. 136 to the Registration Statement on Form N-1A of DWS Global Equity Fund (formerly DWS Diversified International Equity Fund), DWS Emerging Markets Equity Fund, DWS Latin America Equity Fund, and DWS World Dividend Fund (each, a “Fund,” and collectively, the “Funds”), each a series of DWS International Fund, Inc. (the “Corporation”) (Reg. Nos. 002-14400 / 811-00642)
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a.
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Comment: Please confirm that any contractual expense waiver/reimbursement arrangements reflected in a Fund’s fee table will extend for at least one year from the effective date of the Fund’s Prospectus.
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a.
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Comment: In the “Main Risks” sections of the Funds’ Prospectus, consider making the second paragraph of the “Credit Risk” section describing the risks of junk bonds a stand-alone risk section entitled “Junk Bond Risk.”
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b.
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Comment: In the “Main Risk” sections in the “Fund Details” part of the Funds’ Prospectus, the “Foreign Investment Risk” section appears to contain redundant disclosures regarding the liquidity of foreign markets. Please consider modifying this section to eliminate these apparent redundancies.
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a.
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Comment: In disclosure regarding portfolio managers of the Funds, the phrase “joined the fund” is used. Please consider revising the language to clarify that the portfolio manager has joined the fund as a portfolio manager (and not in some other capacity) in the relevant year.
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a.
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Comment: The “Policies About Transactions” section of the Funds’ Prospectus relating to shareholder redemptions discloses that “… when you are selling shares you bought recently by check or ACH (the funds will be placed under a 10 calendar day hold to ensure good funds) ….” Please explain this policy supplementally.
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a.
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Comment: With respect to the Fund’s 80% investment policy, please include disclosure indicating that the term “assets” means “net assets, plus the amount of any borrowings for investment purposes,” as set forth in Rule 35d-1 under the Investment Company Act of 1940.
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b.
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Comment: Please include in the “Principal Investment Strategy” section of the Fund’s Prospectus the Fund’s non-fundamental policy regarding investment exposure to at least three countries and exposure to foreign investments equal to at least 40% of the Fund’s net assets, which policy is recited in Part I of the Fund’s Statement of Additional Information.
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c.
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Comment: For purposes of the Fund’s investment policy that it “may also invest a portion of its assets (typically not more than 35% of its net assets) in securities of companies located in emerging markets, such as those of many countries in Latin America, the Middle East, Eastern Europe, Asia and Africa,” please clarify supplementally what the Fund considers to be an “emerging market.”
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d.
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Comment: Please consider clarifying in the management process description contained in the Fund’s Prospectus what is meant by “risk-balanced bottom-up selection process” since the term “risk-balanced” may suggest low risk.
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a.
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Comment: In the section entitled “Investment Companies and Other Pooled Investment Vehicles” in Part II of the Funds’ Statement of Additional Information, please clarify that a “hedge fund” is a “private fund.”
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b.
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Comment: Please consider modifying the third paragraph of the “Asset Segregation” section in Part II of the Funds’ Statement of Additional Information to clarify the treatment of interpretations and guidance provided by SEC staff.
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