JPMorgan Insurance Trust
1111 Polaris Parkway
Columbus, Ohio 43240
December 19, 2008
VIA EDGAR
Securities and Exchange Commission
100 F Street, N.E.
Washington, DC 20549
Attention: Filing Desk
Re: | JPMorgan Insurance Trust |
Ladies and Gentlemen:
On behalf of JPMorgan Insurance Trust, we hereby submit for filing via EDGAR under Rule 488 of the Securities Act of 1933, the Registration Statement on Form N-14 with respect to the following proposed reorganizations:
ACQUIRED PORTFOLIOS |
| ACQUIRING PORTFOLIOS |
JPMorgan Insurance Trust Government Bond Portfolio and JPMorgan Bond Portfolio
| merges with and into | JPMorgan Insurance Trust Core Bond Portfolio |
JPMorgan International Equity Portfolio
| merges with and into | JPMorgan Insurance Trust International Equity Portfolio |
JPMorgan Mid Cap Value Portfolio
| merges with and into | JPMorgan Insurance Trust Diversified Mid Cap Value Portfolio |
JPMorgan Small Company Portfolio
| merges with and into | JPMorgan Insurance Trust Small Cap Equity Portfolio |
JPMorgan U.S. Large Cap Core Equity Portfolio | merges with and into | JPMorgan Insurance Trust Diversified Equity Portfolio |
The Registration Statement is proposed to become effective on January 17, 2009 pursuant to Rule 488 under the Securities Act of 1933, as amended.
If you have any questions or comments, please call the undersigned at (614) 248-7598.
Sincerely,
/s/ Elizabeth A. Davin |
Elizabeth A. Davin
Assistant Secretary