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Re:
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Kinetics Mutual Funds, Inc. (the “Company”)
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1.
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Staff Comment: In the section beginning with “Letter to Shareholders” on page two, please include in future reports the graphical representation of each Fund’s holdings as required by Item 27 of Form N-1A.
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2.
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Staff Comment: In the “Letter to Shareholders” on page two, with respect to management’s discussion of Fund performance, please include in future reports an explanation for such instances where a Fund has underperformed or reported returns that significantly deviate from its benchmark. For example, for the period covered by the Report, the Water Infrastructure Fund greatly underperformed its benchmark, but an explanation for the underperformance was not included.
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3.
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Staff Comment: In the “Financial Highlights,” as described in Section 5.48 of the Audit Guide please consider including the portfolio turnover of the Trust’s Master Portfolio’s within the “Financial Highlights” of the Company’s Feeder Funds.
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4.
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Staff Comment: In the “Allocation of Portfolio Assets” section for each of the Kinetics Portfolios Trust Portfolios, please consider including in future reports a more detailed graphical representation of each Portfolio’s holdings as required by Item 27 of Form N-1A. For example, where each portfolio invests significantly in common stock, consider depicting sub-categories of investment, such as industry and country, if applicable.
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5.
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Staff Comment: In the Trust’s “Allocation of Portfolio Assets,” please consider clearly clarifying in future reports that the investments made by each Portfolio are based on each Portfolio’s investment objective.
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6.
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Staff Comment: In the Trust’s “Allocation of Portfolio Assets,” with respect to short-term investments, please include in future reports an explanation for circumstances where a Portfolio has held short-term investments. For example, for the period covered by the Report, the Water Infrastructure Portfolio held short-term investments in the amount of 34.7%, but an explanation (e.g. for temporary defensive purposes) for such short-term investment was not included.
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7.
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Staff Comment: In the Trust’s “Statement of Assets & Liabilities,” please provide a brief explanation for the “Payable to Broker” line item.
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(1)
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The Fund acknowledges that in connection with the comments made by the Staff on the Form N-1A registration statement, the Staff has not passed generally on the accuracy or adequacy of the disclosure made in the registration statement;
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(2)
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The Fund acknowledges that Staff comments or changes to disclosure in response to Staff comments in the filings reviewed by the Staff do not foreclose the Commission from taking any action with respect to the filing; and
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(3)
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The Fund represents that it will not assert the Staff’s review process as a defense in any action by the Commission or any securities-related litigation against the Fund.
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cc:
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Drinker Biddle & Reath LLP
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