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<TYPE>EX-99.77E LEGAL
<SEQUENCE>2
<FILENAME>ex77e.txt
<TEXT>
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 and derivative
lawsuits pertaining to market timing have been filed:

There are 15 class and derivative actions that have been
consolidated and transferred to a Multidistrict Litigation in
the District of Maryland ("MDL") (Multidistrict Litigation
1586-In re Mutual Funds Investment Litigation).  The 11
Complaints originally filed in the Southern District of New
York that were transferred to the MDL were virtually
identical and each asserted claims against Deutsche Bank
AG, Deutsche Investment Management Americas Inc. and
Deutsche Asset Management, Inc. as well as approximately
85 Funds in the Scudder family of funds and John Doe
defendants.  The three cases that were originally filed in the
Eastern District of New York and the one case originally
filed in the District of Delaware are derivative actions
brought by purported shareholders in many of the Scudder
Funds.  These actions named Deutsche Investment
Management Americas Inc., Deutsche Asset Management,
Inc., and John Doe defendants.  On September 29, 2004,
two consolidated amended complaints one a consolidated
amended class action complaint and the other a
consolidated amended fund derivative complaint were
filed.

State Case:
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.  On May 27, 2005 the
Northern District of Illinois Court in accord with the 7th
Circuit's mandate dismissed the state law claims with
prejudice.  Plaintiffs filed a cert. petition to the Supreme
Court on September 29, 2005.  On January 6, 2006 the
Supreme Court granted cert. on only the jurisdictional
aspect of the appeal.  Briefing will take in place in February
2006 and March 2006 and oral argument took place on
April 24, 2006.

The following purported class action lawsuits pertaining to
revenue sharing have been filed:

There are 3 class actions that have been consolidated in the
Southern District of New York.  On September 6, 2005,
Walker v. Deutsche Bank AG, et al., Mazza v. Deutsche
Bank AG, et al and Icardo v. Deutsche Bank AG, et al,
were consolidated.  The consolidated Complaint filed on
December 19, 2005 names Deutsche Bank AG, certain
affiliated adviser entities, and Scudder Distributors Inc.


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.


G:\mfld\market timers\Disclosure - Litigation\77e disclosure _ 1-21-05.doc
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