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Get December 19, 2011 By Fax And U.s. Mail Susan S. Rhee, Esq ... - Sec

St Initial Registration Statement on Form N-1A File Nos. 333-177369; 811-22613 Dear Ms. Rhee: The staff has reviewed the above-referenced initial registration statement, which the Commission received on October 18, 2011. The registration statement received a full review. Based on our review, we have the following comments. Page numbers listed are based on the courtesy copy of the filing provided to the staff. 1. General Comments a. Although the funds in the Curian Variable Series Trust (Trust).

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