Skadden,
Arps, Slate, Meagher & Flom llp
FOUR
TIMES SQUARE
NEW
YORK 10036-6522
________
TEL:
(212) 735-3000
FAX:
(212) 735-2000
www.skadden.com
DIRECT
DIAL
212.735.3742
DIRECT
FAX
917.777.3742
EMAIL
ADDRESS
ERIC.REQUENEZ@SKADDEN.COM
June
17, 2009
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VIA
EDGAR
Brion
R. Thompson, Esq.
Securities
and Exchange Commission
Division
of Investment Management
100
F Street, N.E.
Washington,
D.C. 20549
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RE:
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ING
Clarion Real Estate Income Fund ("IIA")
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ING Clarion Global
Real Estate Income Fund
("IGR")
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Dear
Mr. Thompson:
We
received your oral comments on April 7, 2009, May, 11, 2009 and May 21, 2009 to
the Combined Proxy Statement/Prospectus on Form N-14 filed on March 10, 2009
(Nos. 333-157821 and 811-214656) (the "Registration
Statement") pursuant to the Securities Act of 1933 (the "Securities Act") and
the Investment Company Act of 1940 (the "1940 Act") regarding
the reorganization (the "Reorganization") of
IIA with IGR (together with IIA, each, a "Fund" and,
collectively, the "Funds").
The
Funds have considered your comments and have authorized us to make the responses
and changes agreed upon to date to the Registration Statement on the Funds'
behalf. These changes are reflected in Pre-Effective
Amendment No. 1 to the Registration Statement, which is filed
herewith. Copies of the changed pages to the Registration Statement
were submitted to you with our letter dated May 6, 2009, and reflect the changes
made in response to your comments, as well as other
Brion
R. Thompson
Juen
17, 2009
Page
2
changes
made to the Registration Statement since the initial filing. All
changes were conformed throughout the Registration Statement, where
applicable.
"Tandy"
Representation
With
respect to the Registration Statement, IGR hereby acknowledges the
following:
The
disclosure in the filing is the responsibility of IGR. IGR
acknowledges that staff comments or changes in response to staff comments in the
proposed disclosure in the Registration Statement may not be asserted as a
defense in any proceeding which may be brought by any person with respect to
this matter. IGR also represents to the Securities and Exchange
Commission (the "Commission") that
should the Commission or the staff acting pursuant to delegated authority,
declare the filing effective, it does not foreclose the Commission from taking
any action with respect to the filing and IGR represents that it will not assert
this action as a defense in any proceeding initiated by the Commission or any
person under the federal securities laws of the United States.
IGR
further acknowledges, that the action of the Commission or the staff, acting
pursuant to delegated authority, in declaring the filing effective does not
relieve IGR from its full responsibility for the adequacy and accuracy of the
disclosures in the filing.
If
you have any questions or comments or require any additional information in
connection with the above, please telephone me at (212) 735-3742 or Richard
Prins at (212) 735-2790.
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Sincerely,
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/s/ Eric Requenez
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Eric
Requenez, Esq.
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