EX-99.77C VOTES
Shareholder Voting Results
On April 28, 2000, a special meeting of shareholders of Advantus
Spectrum Fund, Inc. was held. Shareholders of record on February 28, 2000,
were entitled to vote on the proposals described below.
(1) To elect a Board of Directors as follows:
Votes Votes
Director For Withheld
Charles E. Arner 3,083,339 197,133
Ellen S. Berscheid 3,090,748 189,724
Ralph D. Ebbott 3,085,028 195,444
Frederick P. Feuerherm 3,091,123 189,349
William N. Westhoff 3,088,419 192,053
(2) To approve the elimination or modification of the following investment
policies for:
Votes Votes Votes
For Against Withheld
A. Modify policy regarding borrowing
and the issuance of senior securities 2,670,477 48,793 229,974
B. Modify policy regarding concentration
in a particular industry 2,673,131 49,927 226,186
C. Modify policy regarding investments
in real estate and commodities 2,683,800 43,824 221,620
D. Modify policy regarding lending 2,680,582 45,897 222,765
E. Eliminate policy restricting
the pledging of assets 2,666,514 58,781 223,949
F. Eliminate policy restricting
margin purchases and short sales 2,659,727 65,385 224,132
G. Eliminate policy prohibiting
participation in a joint trading
account 2,671,529 54,586 223,129
H. Eliminate policy limiting
options transactions 2,674,594 51,488 223,162
I. Eliminate policy limiting
investment in restricted securities
and other illiquid assets 2,674,101 51,289 223,854
J. Eliminate diversification policy 2,665,435 60,573 223,236
K. Eliminate policy regarding
investments in issuers that have been
in operation for less than 3 years 2,679,135 44,951 225,158
L. Eliminate policy addressing
potential conflicts of interest 2,651,515 74,738 222,990
M. Eliminate policy prohibiting
investing in companies for control 2,675,481 47,140 226,623
N. Eliminate policy restricting
investments in other investment
companies 2,673,741 56,142 219,361
(3) To approve an amendment to the
investment advisory agreement between
the Fund and Advantus Capital Management,
Inc., as described in the proxy statement 2,698,832 36,361 214,051
(4) To ratify the selection of KPMG LLP
as independent public accountants for
the Fund 3,031,865 29,149 219,459
