Please file a delaying amendment and pre-effective amendment that includes a consent of independent registered public accounting firm in response to the Staff’s comments.

With respect to the legality of shares opinion provided by Drinker Biddle & Reath LLP, please be advised that in accordance with Staff Legal Bulletin (SLB) No. 19 (Oct. 14, 2011), this opinion is not acceptable. The legality of shares opinion must be provided by a law firm that can affirmatively attest to the conditions and assumptions set forth in the document. The staff has traditionally asked for a binding obligation opinion with respect to the legality of the units. To the extent that Registrant’s counsel believes the units should be treated in a similar fashion as shares of capital stock under applicable state law, the staff may permit an opinion that provides that the units are legally issued, fully paid and non-assessable. As a general rule, the signed legality opinion must be filed as an exhibit to the registration statement before it becomes effective, and it may not be subject to any unacceptable qualifications, conditions or assumptions.

On page 4 of the Q&A, under “How will the Reorganization affect the fees and expenses I pay as a shareholder?” the response states that there is a difference in the way that redemption fees are charged between the two funds. Please revise the Fees and Expenses table to reflect a line item for “Redemption Fees.”

On page 4 of the Q&A, under “How will the Reorganization affect the fees and expenses I pay as a shareholder?” the response states that the net annual operating expense ratio of each of the Kinetics Fund's Classes of shares is not expected to be materially different from that of the Horizon Fund's Classes of shares for the first two years after the Reorganization; however, the fees and expenses table denotes a change in the total annual fund operating expenses (“gross total expenses”) of the Kinetics Fund.  Please provide an explanation for the discrepancy.

On page 4, under the paragraph titled, “Relative Expenses and Continuation of Limitation on Expenses,” please describe the Board’s consideration of the change in Fund operating expenses of Class A and Institutional Class shares.

On page 15, under the heading titled, “Comparison of Fees and Expenses,” please explain the difference in the “Other Expenses” with respect to the shareholder servicing fees between each of the Classes of shares of the Kinetics Fund and the Horizon Fund.

On page 15, under the heading titled, “Comparison of Fees and Expenses,” please explain why the Kinetics fund will not incur acquired fund fees and expenses (“AFFE”).

Under the heading titled, “Comparison of Fees and Expenses,” please clarify footnote 5 with respect to the recapture/recoupment provision with respect to the fact that reimbursement amounts may be requested within three years of incurring the applicable expenses, if the aggregate amount actually paid by the Fund toward operating expenses for the fiscal year (taking into account the reimbursement) does not exceed the Expense Cap at the time of waiver or reduction of fees, whichever is lower. In addition, please confirm that any recapture provision is limited to the lesser of the Expense Cap in effect at the time of the waiver and the Expense Cap in effect at the time of recapture.

Page 21 states that “Institutional Class shares of the Kinetics Fund will not pay any Rule 12b-1 fees, but will pay 0.05% in shareholder servicing fees.” This sentence is not consistent with the Fees and Expenses table. Please clarify and make consistent.

On page 23 under the heading titled, “Federal Income Tax Consequences,” please include disclosure regarding any capital loss carryforwards and any limitations on the capital loss carryforwards.

On page 27 under the heading titled, “Capitalization,” please confirm and disclose if the Kinetics Fund will be the accounting survivor in this transaction.

On page 27 under the heading titled, “Capitalization,” please complete the table.

On page 28 under the heading titled, “Capitalization,” please disclose whether or not prior amounts waived by the Horizon Fund will be subject to recoupment by the adviser to the Kinetics Fund. If so, please disclose the amounts subject to recoupment and a timetable of recoupment.

With respect to Appendix D, please update the financial highlights tables to include April 30, 2017 audited financial information and review and confirm that all figures are accurate.