Subject: File No. S7-15-10
From: David R Wilson
Affiliation: PhD of Chemistry

October 18, 2010

12b fees should not be imposed on mutual fund holders unless there is a direct benefit to the shareholders such as research. Use of the fees for marketing purposes, administrative fees and the like is a misuse of shareholder money and does not increase the value of the fund to the owners, the shareholders and should be opposed.