1.

Please clarify/define “under certain market conditions” in the last sentence of the 2nd paragraph of the Principal Investment Strategy section: In addition, under certain market conditions, the Kinetics Fund may invest in a company at the time of its initial public offering (“IPO”).

2.

Please clarify/define “future” in the following sentence: The Fund may invest up to 20% of its assets in companies that, for a variety of reasons, the Fund's sub-advisor believes may have the potential to be subject to a future spin-off or corporate restructuring, including instances in which a similar company may have recently announced a spin-off; the company may be under investor pressure to consider strategic alternatives.

3.

With respect to the Fees and Expenses table, please clarify footnote 4 with respect to the recapture/recoupment provision to show 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.

4.

Please revise the “Principal Investment Strategy” section on page 4 of the Prospectus to state that the Kinetics Fund is non-diversified.

5.

Please complete all open items in the Prospectus and Statement of Additional Information.

6.

In the “Distribution of Shares” section under the subheading titled, “Rule 12b-1 Plan,” please state that the Fund is currently charging 0.25%.

7.

In the “Financial Highlights” introductory paragraph, please add a reference to the Predecessor Fund’s auditor.

8.

Please update the “Financial Highlights” tables to include information for the fiscal year ended April 30, 2017.

9.

With respect to Appendix A of the Prospectus, please confirm to the Staff that all intermediaries offering sales charge waivers or variations are included in the disclosure and that the term “waiver” means a full and not a partial waiver. Please review the disclosure to state if there is a partial waiver.