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DORSEY & WHITNEY LLP
MINNEAPOLIS PILLSBURY CENTER SOUTH BILLINGS
220 SOUTH SIXTH STREET
NEW YORK MINNEAPOLIS, MINNESOTA 55402-1498 GREAT FALLS
TELEPHONE: (612) 340-2600
SEATTLE FAX: (612) 340-2868 MISSOULA
DENVER BRUSSELS
WASHINGTON, D.C. FARGO
DES MOINES HONG KONG
ANCHORAGE ROCHESTER
LONDON SALT LAKE CITY
COSTA MESA VANCOUVER
Advantus Real Estate Securities Fund, Inc.
400 Robert Street North
St. Paul, Minnesota 55101
Ladies and Gentlemen:
We have acted as counsel to Advantus Real Estate Securities
Fund, Inc., a Minnesota corporation (the "Fund"), in connection with a
Registration Statement on Form N-1A (File No. 333-68669) (the "Registration
Statement") relating to the sale by the Fund of an indefinite number of
shares of the Fund's Class A Common Shares, Class B Common Shares and Class C
Common Shares, each with a par value of $.01 per share (the "Shares").
We have examined such documents and have reviewed such questions of
law as we have considered necessary and appropriate for the purposes of our
opinions set forth below. In rendering out opinions set forth below, we have
assumed the authenticity of all documents submitted to us as originals, the
genuineness of all signatures and the conformity to authentic originals of all
documents submitted to us as copies. We have also assumed the legal capacity for
all purposes relevant hereto of all natural persons and, with respect to all
parties to agreements or instruments relevant hereto other than the Fund, that
such parties had the requisite power and authority (corporate or otherwise) to
execute, deliver and perform such agreements or instruments, that such
agreements or instruments have been duly authorized by all requisite action
(corporate or otherwise), executed and delivered by such parties and that such
agreements or instruments are the valid, binding and enforceable obligations of
such parties. As to questions of fact material to our opinions, we have relied
upon certificates of officers of the Fund and of public officials. We have also
assumed that the Shares will be issued and sold as described in the Registration
Statement.
Based on the foregoing, we are of the opinion that upon issuance,
delivery and payment for the Shares as described in the Registration Statement,
the Shares will be validly issued, fully paid and nonassessable.
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DORSEY & WHITNEY LLP
Advantus Real Estate Securities Fund, Inc.
September 28, 2000
Page 2
We hereby consent to the filing of this opinion as an exhibit to
the Registration Statement and to the reference to our firm under the caption
"Service Providers" in the Prospectus which constitutes a part of the
Registration Statement.
Dated: September 28, 2000
Very truly yours,
/s/ Dorsey & Whitney LLP
Dorsey & Whitney LLP
MJR
