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<TYPE>EX-99.77E
<SEQUENCE>3
<FILENAME>r77e.txt
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77E                          Legal Proceedings


PIMCO Commercial Mortgage Securities Trust, Inc.

On February 17, 2004, the Attorney General of New Jersey filed a complaint
against Allianz Dresdner Asset Management of America L.P. ("ADAM"); PIMCO
Advisors Distributors LLC ("PAD"); PEA Capital LLC (formerly known as PIMCO
Equity Advisors LLC) ("PEA"); and Pacific Investment Management Company LLC
("PIMCO") in connection with its investigation into market timing and late
trading.  The complaint alleges, among other things, that inappropriate
trading by shareholders engaged in market timing activity took place in funds
in the PIMCO Funds: Multi-Manager Series ("MMS Funds") and the PIMCO Funds:
Pacific Investment Management Series ("PIMS Funds").  On February 17, 2004,
a putative class action lawsuit was filed in the United States District Court
for the District of Connecticut on behalf of certain shareholders of the PIMCO
Funds against ADAM, PEA, PIMCO, PIMS Funds, MMS Funds and certain other
defendants, alleging that the investment advisers to certain of the MMS Funds
and PIMS Funds inappropriately used fund assets to pay brokers to promote the
Funds by directing fund brokerage transactions to such brokers and did not
fully disclose such arrangements to shareholders. On February 20, 2004, a
putative class action lawsuit was filed in the United States District Court
for the District of New Jersey on behalf of certain shareholders of the PIMCO
Funds against ADAM, PAD, PIMCO, PEA, PIMS Funds, MMS Funds, PIMCO Variable
Insurance Trust, PIMCO Commercial Mortgage Securities Trust, Inc. and certain
other defendants, relating to the same facts that are the subject of the
regulatory proceedings discussed above. Both of the class action lawsuits
seek unspecified compensatory damages.  ADAM and the PIMCO-related entities
are conducting a thorough internal investigation into the matters raised in
the complaints.  The New Jersey Attorney General's complaint does not allege
any market timing activity took place in the Fund, and the class action
complaint filed in Connecticut does not name the Fund as a party.

These legal and regulatory developments do not relate to closed-end investment
companies such as the Fund.  Although it is not possible to predict what, if
any, effect the foregoing will have on the market for shares of the Fund,
PIMCO has notified the Fund that PIMCO does not believe that these
developments will have a material adverse effect on PIMCO's ability to
perform its advisory services to the Fund.





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