SEC Division of Corporation Finance no-action letter: CurrencyShares British Pound Sterling Trust

Rydex Specialized Products LLC, as sponsor of the CurrencyShares British Pound Sterling Trust, requests no-action relief from the certification rules in Exchange Act Rules 13a-14(a) and 15d-14(a) and Item 601(b)(31) of Regulation S-K. The request seeks confirmation that the Staff will not recommend enforcement action if certifications filed with the Trust's periodic reports, signed by the Sponsor's CEO and CFO, deviate from the specific form required by Item 601(b)(31). This relief applies to the Trust's quarterly and annual reports due to the Sponsor's structure and the Trust's passive nature.

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"FOLEY

FOLEY & LARDNER LLP
FOLEY & LARDNER LLP
ATTORNEYS AT LAW
ONE DETROIT CENTER
500 WOODWARD AVENUE, SUITE 2700
DETROIT, MI 48226-3489
313.234.7100 TEL
313,2342800 FAX
VIA E-MAIL www.fo1ey.com
CLIENT/MATTER NUMBER
058081-0106
September 6,2006
Securities Exchange Act of 1934
Rules 13a-14(a) and 15d-14(a) and
Item 601 (b)(3 1) of Regulation S-K

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

Re: Rydex Specialized Products LLC dlbla "Rydex Investments", Sponsor of

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