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<TYPE>EX-99.77E LEGAL
<SEQUENCE>3
<FILENAME>ex77e_txt.txt
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Regulatory Update

As previously reported in the press, a number of private
lawsuits have been filed including purported class action and
derivative lawsuits, making various allegations and naming as
defendants various persons, including certain Scudder funds,
the funds' investment advisors and their affiliates, certain
individuals, including in some cases fund Trustees/Directors,
officers, and other parties.  Each Scudder fund's investment
advisor has agreed to indemnify the applicable Scudder funds
in connection with these lawsuits, or other lawsuits or
regulatory actions that may be filed making allegations similar
to these lawsuits regarding market timing, revenue sharing,
fund valuation or other subjects arising from or related to the
pending inquiries.  Based on currently available information,
the funds' investment advisors believe the likelihood that the
pending lawsuits will have a material adverse financial impact
on a Scudder fund is remote and such actions are not likely to
materially affect their ability to perform under their
investment management agreements with the Scudder funds.

The following purported class action lawsuits have been filed:

(1) On September 16, 2003, in the Circuit Court for Madison
County, Illinois entitled Potter v. Janus Investment Fund, et al.
Defendants include, among others, Deutsche Investment
Management Americas ("DIMA"), Inc., and Scudder
International Fund.  (2) On May 12, 2004, in the United States
District Court for the Southern District of New York entitled
Icardo v. Deutsche Bank AG, et al.  Defendants include,
among others, Deutsche Bank AG, DeAM, DIMA, Scudder
Investments, Scudder Funds, and certain Directors/Trustees of
the Scudder Funds.  (3) On September 29, 2004, the following
complaint, In re Mutual Funds Investment Litigation,
consolidating the previously filed class action lawsuits was
filed in conjunction with the multi-district litigation panel
sitting in the United States District Court for the District of
Maryland.  The defendants include the Scudder Funds, their
Directors/Trustees and Officers and former Directors/Trustees
and Officers, Deutsche Bank AG and certain investment
adviser affiliated, employees and former employees.

The following derivative lawsuit was filed:

On September 29, 2004, the following complaint, Hinton v.
Deutsche Bank AG, et al., consolidating the previously filed
class action lawsuits was filed in conjunction with the multi-
district litigation panel sitting in the United States District
Court for the District of Maryland.  The defendants include
the Scudder Funds, their Directors/Trustees and Officers and
former Directors/Trustees and Officers, Deutsche Bank AG
and certain investment adviser affiliated, employees and
former employees.

The following combined purported class action and derivative
lawsuits have been filed:

(1) On March 10, 2004, in the United States District Court for
the Southern District of New York entitled Walker v.
Deutsche Bank AG, et al.  Defendants include, among others,
Deutsche Bank AG, DeAM, DIMA, Scudder Investments, and
certain Directors/Trustees of the Scudder funds.  (2) On May
6, 2004, in the United States District Court for the Southern
District of New York entitled Mazza v. Deutsche Bank AG, et
al.  Defendants include, among others, Deutsche Bank AG,
DeAM, DIMA, Scudder Investments, and certain
Directors/Trustees of the Scudder funds.


In addition to the market timing, revenue sharing and
valuation litigation discussed above the following unrelated
purported class action lawsuit has been filed:

On January 12, 2005, in the United States District Court for
the Southern District of New York entitled McMunn and
Raimo v. Deutsche Bank Americas Holding Corporation, et
al.  Defendants include among others, Deutsche Bank
Americas Holding Corporation, DeAM, Inc., Scudder
Investors Services, Inc., and certain Directors/Trustees of the
Scudder Funds.  The lawsuit alleges the defendants breached
their fiduciary duties and violated the Investment Company
Act of 1940 by failing to collect settlement funds awarded in
investor class action lawsuits for securities held by the
Scudder Funds.

Based on currently available information, the funds'
investment advisors believe the likelihood that this January
12, 2005 pending lawsuit will have a material adverse
financial impact on a Scudder fund is remote and such action
is not likely to materially affect their ability to perform under
their investment management agreements with the Scudder
funds.

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