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DORSEY & WHITNEY LLP
Advantus Spectrum Fund, Inc.
400 Robert Street North
St. Paul, Minnesota 55101
Ladies and Gentlemen:
We have acted as counsel to Advantus Spectrum Fund, Inc., a
Minnesota corporation (the "Fund"), in connection with a Registration Statement
on Form N-1A (File No. 2-94175) (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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Advantus Spectrum Fund, Inc.
November 27, 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: November 27, 2000
Very truly yours,
/s/ DORSEY & WHITNEY LLP
MJR
