SEC Division of Corporation Finance no-action letter: CurrencyShares Swiss Franc Trust

Rydex Specialized Products LLC requests no-action relief from the certification requirements of Exchange Act Rules 13a-14(a) and 15d-14(a) and Item 601(b)(31) of Regulation S-K for the CurrencyShares Swiss Franc Trust. The Sponsor seeks confirmation that the Staff will not recommend enforcement action if the Certifications filed with the Trust's periodic reports, signed by the Sponsor's CEO and CFO, deviate from the standard form prescribed in Item 601(b)(31). This request addresses the specific structural arrangement where the Trust has no employees and the Sponsor relies on affiliates for operational services.

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"FOLEY

FOLEY & LARDNER LLP
FOLEY & LARDNER LLP
ATTORNEYS AT LAW
ONE DETROIT CENTER
500 WOOOWARO AVENUE, SUITE 2700
DETROIT. MI 48226-3489
313.234.7100 TEL
313.234.2800 FAX
VIA E-MAIL www.loley.com
CLIENT/MATTER NUMBER
058081-0108
September 6,2006
Securities Exchange Act of 1934
Rules 13a-14(a) and 15d-14(a) and
Item 601(b)(31) of Regulation S-K
Securities and Exchange Commission

I00 F Street, N.E.

Washington, D.C. 20549
Re: Rydex Specialized Products LLC d/b/a "Rydex Investments", Sponsor of CurrencyShares Swiss Franc Trust (File No. 333-132364); Certification Rules for Quarterly and Annual Reports set forth in Exchange Act Rules 13a-14(a) and 15d-14(a) and Item 601(b)(31) of Regulation S-K Ladies and Gentlemen:
This letter revises and replaces our letter to you dated August 16, 2006, which is

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