Fidelity Select Portfolios: Omission of Shareholder Proposals from Proxy Statement — SEC — US

FIDELITY SELECT PORTFOLIOS

Electronics Portfolio

Natural Resources Portfolio

VIA ELECTRONIC MAIL: imshareholderproposals@sec.gov January 30, 2013 U.S. Securities & Exchange Commission 100 F Street NE Washington, DC 20549 Attn: Office of Disclosure and Review Re: Shareholder Proposals for Electronics Portfolio and Natural Resources Portfolio, series of Fidelity Select Portfolios (File No 811-03114) Ladies and Gentlemen:
On April 6, 2009, a letter from Mr. Bruce Seltzer was received at the principal executive offices of Natural Resources Portfolio, and on May 29, 2010, a letter from Ms. Lisa Guravitz and Mr. Frederick Shaw was received at the principal executive offices of Electronics Portfolio (together with Natural Resources Portfolio, the "Funds"). The letters request that a proposal be submitted to shareholders at the next scheduled meeting for the Funds. As detailed in the letters, copies of which are attached, the proposal requests that the Board of Trustees of each Fund implement certain procedures to prevent the Fund from holding investments in companies that, m management's judgment, substantially contribute to genocide or crimes against humanity. Pursuant to Rule 14a-8(b )( 1 ), to be eligible to submit a proposal, a shareholder must have continuously held at least $2,000 in market value, or 1%, of the company's securities entitled to be voted on the proposal at the meeting for at least one year by the date the proposal is submitted, and must continue to hold those securities through the date of the meeting. Upon receipt of the letters, Natural Resources Portfolio and Electronics Portfolio verified that Mr. Seltzer and Ms. Guravitz/Mr. Shaw, respectively, met the eligibility requirements to submit a proposal pursuant to Rule 14a-8(b)(1 ). In preparation for an upcoming shareholder meeting, the Funds recently attempted to verify that the proponents continue to satisfy the eligibility requirements of Rule 14a-8(b )( 1 ). The Funds determined that the proponents were not record owners of any Fund shares. On October 18, 2012, we sent letters (copies of which are attached along with confirmation of delivery) to the proponents to request that they provide the information necessary to confirm that they continue to meet the requirements of Rule 14a-8(b)(l). To date, the proponents have not responded to the Funds' request and have not provided the information necessary to permit the Funds to confirm that the proponents continue to satisfy the requirements of Rule 14a-8(b )( 1 ). The next shareholder meeting for the Funds is scheduled to be held on or about May 14, 2013. Because the Natural Resources Portfolio and the Electronics Portfolio are unable to confirm, based on their records, that Mr. Seltzer and Ms. Guravitz/Mr. Shaw, respectively, continue to be shareholders of the Funds and have continuously held the requisite amount of Fund shares since Legal Department 82 Devonshire Street V1 OE Phone: 617 563-7000 Boston , MA 02109

submitting their proposal as required by Rule 14a-8(b )(1) and because the proponents have not responded to requests to provide additional holdings information, we intend to omit this proposal from the proxy statement for the Funds as permitted by Rule 14a-8(t)(2). If you have questions or comments concerning this matter, please contact Megan C. Johnson at Dechert LLP at (202) 261-3300. ;;~JJJJ Scott C. Goebel

Secretary of the Trust

Enclosures:

October 18,2012 Letter to Bruce Seltzer

April6, 2009 Letter from Bruce Seltzer (w/o enclosures)

October 18, 2012 Letter to Lisa Guravitz and Frederick Shaw

May 29, 2010 Letter from Lisa Guravitz and Frederick Shaw (w/o enclosures)

cc: Bruce Seltzer
Lisa Guravitz and Frederick Shaw
Edward Bartz, U.S. Securities and Exchange Commission Legal Department 82 Devonshire Street V1 OE Phone: 617 563-7000 Boston, MA 02109

FIDELITY SELECT PORTFOLIOS

Select Natural Resources Portfolio

VIA OVERNIGHT MAIL
October 18, 2012
Mr. Bruce Seltzer
315 Prospect Street
Northampton, MA 01060
Dear Mr. Seltzer:
On April 27, 2009, your shareholder proposal, dated April 6, 2009, was received in the principal executive offices of Select Natural Resources Portfolio (the "Fund"), a series of Fidelity Select Portfolios (the "Trust"). Rul e 14a-8(b)(l) provides that in order to be eligible to submit a proposal for inclusion in a proxy statement for the Fu nd, a shareholder must have "continuously held at least $2,000 in market value, or 1%, of the company's securities entitled to be voted on the proposal at the meeting for at least one year by the date [the shareholder] submit[s] the pro posal and " must continue to hold those securities through the date of the meeting." As required by Rule 14a-8(b)(2), you have provided a written statement that you "intend to meet Rule 14a-8 requirements including the continuous ownersh ip of the required stock val ue until after the date ofthe respective shareholder meeting." Upon receipt of your proposal, we verified that you in itially met the eligibility requirements to submit a proposal pursuant to Rule 14a-8(b)(l). However, based on a review of the Fund's records, we are unable to confirm that you continue to hold the amou nt of Fund shares required under Rule 14a-8(b )( 1 ). As provided in Rule 14a-8(b )(2), we request that you provide us with information about your holdings so that we may verify your continued eligibility to submit a shareholder proposal for the Fund . By this letter we hereby provide you with the opportunity to provide us with information regarding your holdings with respect to shares of the Fund so that we may verify that you have continuously held the requisite amount of Fund shares and, thus, continue to be eligible to submit a shareholder proposal for the Fund. We request that your response be postmarked, or transmitted electronically, no later than 14 days from the date you receive this notification. Please direct all further correspondence with respect to this shareholder proposal to: Fund Shareholder Meetings, 82 Devonshire Street, Mailzone V10A, Boston, MA 02110 or (617) 385 -1331 (fax). This letter shall not be deemed to waive any right of the Fund to omit any proposal from the proxy materials for the Fund 's next shareholders' meeting for any other reason. Sincerely, ~llc4iV Scott C. Goe bel Secretary of the Trust Lega l Departm ent

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315 Prospect Street
Northampton, MA 01 060
April 6, 2009
Secretary
Fidelity Select Natural Resources Fund (FNARX) 82 Devonshire Street Boston, MA 02109 Re : Shareholder Proposal Dear Secretary:
I am writing to submit the enclosed shareholder proposal for inclusion in the fund's next proxy statement and for presentation at the next shareholder meeting. I am hoping that once it is on the ballot, you will take a favorable (or at least neutral) position with regard to the proposal. I hold a total of shares of . elity srevNatural Resources Fund; of these 00 shares are in my Fidelity 403b Account# and (!) shares are in my Fidelity 403b Account

61P417 .

I am also enclosing a statement of each of the foregoing accounts confirming my ownership of said shares. I have continuously held at least $2,000 of Fidelity Small Select Natural Resources Fund for over a year and it is my intention to continue to do so. Please confmn receipt ofthis letter. If for any reason you choose to exclude this proposal from your proxy please notify me at the above address . Other shareholders may have submitted this shareholder proposal in support of a campaign initiated by Investors Against Genocide. If another shareholder has already submitted the same proposal, please consider this a joint submission in support of his I her proposal. Thank you for your attention to this matter. Sincerely, Enclosures ( 4) cover letter resolution two statements

FIDELITY SELECT PORTFOLIOS

Select Electronics Portfolio

VIA OVERNIGHT MAIL
October 18, 20 12
Ms. Lisa Guravitz and Mr. Frederick Shaw

349 Ash Ave SPC 25

Carpenteria. CA 93013 - 2272

Dear Ms. Guravitz and Mr. Shaw:
On June 4, 2010, your shareholder proposal, dated May 29, 2010, was received in the principal executive offices of Select Electronics Portfolio (the "Fund"), a series of Fidelity Select Portfolios (the "Trust"). Rule 14a-8(b )( 1) provides that in order to be eligible to submit a proposal for inclusion in a proxy statement for the Fund, a shareholder must have "continuously held at least $2,000 in market value, or 1%, of the company's securities entitled to be voted on the proposal at the meeting for at least one year by the date [the shareholder] submit[s] the proposal and "must continue to hold those securities through the date of the meeting. " As required by Rule 14a-8(b)(2), you have provided a written statement that you "intend to meet Rule 14a-8 requirements including the continuous ownership of the required stock value until after the date ofthe respective shareholder meeting." Upon receipt of your proposal, we verified that you initially met the eligibility requirements to submit a proposal pursuant to Rule 14a-8(b)(l). However, based on a review of the Fund's records, we are unable to confirm that you continue to hold the amount of Fund shares required under Rule 14a-8(b )( 1 ). As provided in Rule 14a-8(b )(2), we request that you provide us with information about your holdings so that we may verifY your continued eligibility to submit a shareholder proposal for the Fund . By this letter we hereby provide you with the opportunity to provide us with information regarding your holdings with respect to shares of the Fund so that we may verify that you have continuously held the requisite amount of Fund shares and, thus, continue to be eligible to submit a shareholder proposal for the Fund. We request that your response be postmarked, or transmitted electronically, no later than 14 days from the date you receive this notification. Please di rect all further correspondence with respect to this shareholder proposal to: Fund Shareholder Meetings, 82 Devonshire Street, Mailzone V 1 OA, Boston, MA 02110 or ( 617) 3 85-13 31 (fax). This letter shall not be deemed to waive any right of the Fund to omit any proposal from the proxy materials for the Fund's next shareholders' meeting for any other reason. Sincerely, ;/ ;;' _, )J/;1 ('') //j~ f { _; {/ri- , Scott C. Goebel Secretary of the Trust Legal Depa rtment

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Lisa Guravitz

Frederir,k Sh8w

349 ASH AVE SPC 25

CARPINTERIA . CA 93013 - 2272

May 29. 2010
Secretary of the Trust) Attention "Fund Shareholder Meetings" Fidelity Investments 82 Devonshire Street, Mailzone V1 OA Boston. Massachusetts 02109 To the Secretary:
We are writing to submit the enclosed shareholder proposals to 6 Fidelity funds for inclusion in their next proxy statements and for presentation at their next shareholder meetings. We hope that once they are on the ballot) you will take a favorable ) or at least neutral, stance with regard to the proposal. The funds and the number of sh8res I own of enr.h ~m~·
1) Fidelity Balanced Fund (FBALX) ~§.4§ shares
2) Fidelity Select Computers Portfolio (FDCPX) 82 shares
3) Fidelity Cash Reserves (FDRXX) 91.053 shares
4) Fidelity GNMA Fund (FGMNX) 1456 shares_
5) Fidelity Mortgage Securities Fund (FMSFX) 12.742 shares
6) Fidelity Select Electronics Portfolio (FSELX) 449 shares
We are also enclosing a statement of our Fidelity accounts which confirms our ownership of said shares . We have continuously held at least $2,000 of each of the six funds for over a year and it is our intention to continue to do so. Please confirm receipt of this cover letter and six shareholder proposals . If for any reason you choose to exclude this proposal from your proxy please notify us at the above address. Other shareholders may have submitted this shareholder proposal in support of a campaign initiated by Investors Against Genocide. If another shareholder has already submitted the same proposal, please consider this a joint submission in support of his/her proposal. Thank you for your consideration . Sincerely, / ~A~ Frederick Shaw