SEC Division of Trading and Markets no-action letter: streetTRACKS Gold Trust

. 570 Lcringion Avenue
NN ~ork m 10022 DEC O 2 2004 Te1 (212) 732-3200 (212) 371-2720 Fa (212) 732-3232 1401 Eye Stmer. N. N! Washington. DC 2WO5 (202) 898-1515 James Brigagliano, Esq. Assistant Director, Trading Practices Office of Trading Practices and Processing Division of Market Regulation Securities and Exchange Commission 450 Fifth Street, N.W. Washington, DC 20549 Re: Request of World Gold Trust Services, LLC for Exemptive, Interpretative or No-Action Relief from Rule loa-1 under, Rules 101 and 102 of Regulation RI under, Section ll(d)(l) of, and Rule lldl-2 under the Securities Exchange Act of 1934, as amended. Dear Mr. Brigagliano:
We are writing on behalf of World Gold Trust ~enl&es, LLC, the sponsor ("S~onsor") of the S~~~~~TRACKS~ Gold Trust ("Trust"). The Sponsor, on behalf of itself, the Trust, UBS Securities LLC ("Purchaser"), as undenvriter of the Undenvritten Shares (defined below), State Street Global Markets, LLC, as marketing agent for the Trust ("Marketing A~ent"), the New York Stock Exchange ("NYSE") and any other national securities exchange or national securities association (each, an "Other Exchange") (NYSE and Other Exchange collectively referred to as "Exchan~e") and persons or entities engaging in transactions in units of fractional undivided beneficia1 interest in, and ownership of, the Trust hare res")', hereby requests, as appropriate, from the Staff of the Securities and Exchange Commission ("Commission") or from the Cornmission, exemptions from, or interpretive or no-action advice or relief regarding Rule 1 Oa-1 under, Rules 10 1 and 102 of Regulation M under, Section 1 1 (d)(l ) of, and Rule 1 1 d 1-2 under the Securities Exchange Act of 1934, as arnended ("Exchange ~ct").~ 1 street~~~~~~~ is a registered service mark of State Street Corporation, an affiliate of State Street Global Markets, LLC, the marketing agent of the Trust. 2 If the Sponsor, on behalf of the Trust, ultimately lists the Shares on an Other Exchange, the Shares will be listed in accordance with the Other Exchange's listing standards that are, or will become, effective pursuant to Section 19(b) of the Exchange Act. If the Shares also trade on an Other Exchange pursuant to unlisted trading privileges, such trading will be conducted pursuant to self-regulatory organization rules that have become effective pursuant to
Section 19(b) of the Exchange Act. See also footnote 6 and related text, rnfra
1273388.5