<DOCUMENT>
<TYPE>EX-99.77E LEGAL
<SEQUENCE>3
<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 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.  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.  (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.


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