<DOCUMENT>
<TYPE>EX-99.77E LEGAL
<SEQUENCE>2
<FILENAME>ex77e.txt
<DESCRIPTION>LEGAL LETTER
<TEXT>
Litigation Update

Federal Court Market Timing Litigation:
A number of private lawsuits have been filed
including purported class and derivative
lawsuits, making various allegations and
naming as defendants various persons,
including certain Scudder and Deutsche (now
DWS) funds (singularly, a "Fund" and
collectively, the "Funds"), the Funds'
investment advisors and their affiliates,
certain individuals (including in some cases
Fund Trustees/Directors, officers), and other
parties.  Each Fund's investment advisor has
agreed to indemnify the applicable 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
related to investigations of the foregoing
matters.  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 Fund is remote and such
actions are not likely to materially affect
their ability to perform under their
investment management agreements with the
Funds.

Fifteen (15) class and derivative actions
pertaining to market timing have been
consolidated and transferred to a
Multidistrict Litigation Panel 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. ("DIMA") and Deutsche
Asset Management, Inc. as well as
approximately 85 Funds in the Scudder and
Deutsche 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
certain of the Funds.  These actions are
against 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 in the MDL.

On January 11, 2006, Plaintiffs filed a Second
Consolidated Amended Class Action Complaint in
the MDL.  The officer defendants have been
voluntarily dismissed from the class action
pursuant to a tolling agreement with
Plaintiffs.  Deutsche Bank AG has been
dismissed from the derivative action.  On
March 16, 2007, the Court issued an opinion in
the MDL granting in part and denying in part
the Deutsche Defendants' motion to dismiss the
Second Consolidated Amended Class Action
Complaint.

Plaintiffs filed a Third Consolidated Amended
Class Action Complaint ("Third Amended
Complaint") on December 10, 2007 in the MDL.
In the Third Amended Complaint, the
Plaintiffs added the names of Funds that they
allegedly purchased or held during the class
period. In addition, as contemplated in the
Court's scheduling order, the Third Amended
Complaint added a new Plaintiff in an attempt
to address standing challenges raised by the
Defendants.  On January 16, 2008, the Court
granted in part and denied in part the
Defendants' motion to dismiss certain claims
on standing grounds.  Extensive discovery has
been undertaken.  On July 2, 2008, the
Defendants filed their motion for summary
judgment and various related motions, and
Class Plaintiffs filed their motion for class
certification.  Oppositions to these motions
are due on September 24, 2008, and reply
briefs are due on November 5, 2008.  The Court
has scheduled a hearing for these motions on
December 10-11, 2008.

State Court Market Timing Litigation:
On September 16, 2003, an action was commenced
in the Circuit Court for Madison County,
Illinois, entitled Potter v. Janus Investment
Fund, et al.  Defendants include, among
others, DIMA and the Scudder International
Fund. On October 23, 2003, Defendants removed
the action to the United States District Court
for the Southern District of Illinois. On
February 9, 2004 the District Court remanded
the case back to the Circuit Court for Madison
County.  Defendants appealed this decision.
On April 5, 2005 the Seventh Circuit Court of
Appeals reversed the District Court's decision
and instructed the District Court to undo the
remand order and dismiss the complaint.  On
May 27, 2005, the District Court, in accord
with the Seventh Circuit's mandate, dismissed
the action with prejudice.  On September 29,
2005, Plaintiffs filed a petition for a writ
of certiorari to the Supreme Court of the
United States.  On January 6, 2006, the
Supreme Court granted the petition to address
jurisdictional questions.  On June 15, 2006,
the Supreme Court vacated the decision of the
Seventh Circuit and held that the Court of
Appeals did not have jurisdiction to address
the District Court's remand order.  The case
was remanded to and reopened in the Circuit
Court for Madison County.  On November 13,
2006, Defendants removed the case to Federal
District Court for a second time.  On April 6,
2007, the District Court remanded the case
back to the Circuit Court for Madison County.
Defendants appealed this decision to the
Seventh Circuit, which dismissed the appeal
for lack of jurisdiction on July 13, 2007.
The case is now back in the Circuit Court for
Madison County.  We argued Defendants' motion
to dismiss in August 2007 and are awaiting the
Circuit Court's decision.  On July 23, 2008,
we received an Order from the Circuit Court
dated July 16, 2008 in which the Court stated
that the issues raised by the motion to
dismiss are nearly identical to those in a
pending appeal in another action, and that the
Court would therefore wait for the decision of
the Illinois Appellate Court before ruling on
the motion to dismiss.

Federal Court Revenue Sharing Litigation:
The following purported class actions
pertaining to revenue sharing were filed in
the Southern District of New York: Walker v.
Deutsche Bank AG, et al., Mazza v. Deutsche
Bank AG, et al. and Icardo v. Deutsche Bank
AG, et al.  These three class actions were
consolidated. The consolidated Complaint filed
on December 19, 2005 named as defendants
Deutsche Bank AG, certain affiliated adviser
entities, and Scudder Distributors Inc.  On
August 15, 2007, the Court granted the
Defendants' motion to dismiss with prejudice
and denied Plaintiffs' request for leave
to amend the complaint.  The Plaintiffs did
not appeal, and the deadline for appealing
this decision has now passed.

Updated 7-28-08

DB1/62009303.1
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