EXHIBIT 77.O
77.O TRANSACTIONS EFFECTED PURSUANT TO RULE 10F-3
Columbia Special Fund, Inc.:
Qualifying transactions are listed below. On a quarterly
basis, the Registrant's Board of Directors receives a Form
10F-3 containing information that enables them to determine
that all purchases made during the quarter were effected in
compliance with the Registrant's 10F-3 procedures.
1) Issuer: Sycamore Networks, Inc.
Date of Purchase: 3/14/2000
Underwriter from whom Purchased:
First Boston (Credit Suisse)
Affiliated Underwriters:
Robertson Stephens
Other Members of Syndicate:
Morgan (JP) & Co.
Lehman Brothers
Dain Rquscher Wessels
Morgan Stanley Dean Witter
Thomas Weisel Partners LLC
Aggregate dollar amount of purchase:
$56,343,750
Aggregate dollar amount of offering:
$253,750,000
Purchase price (net of fees and expenses):
$146.83 per share
Date offering commenced:
3/14/2000
Commission: $3.42
2) Issuer: Sonus Networks
Date of Purchase: 5/24/2000
Underwriter from whom Purchased:
Goldman Sachs & Co.
Affiliated Underwriters:
FleetBoston Robertson Stephens
Other Members of Syndicate:
Morgan (JP) & Co.
Lehman Brothers
Aggregate dollar amount of purchase:
$115,000
Aggregate dollar amount of offering:
$115,000,000
Purchase price (net of fees and expenses):
$22.04
Date offering commenced:
5/24/2000
Commission: $0.96
3) Issuer: ONI Systems
Date of Purchase: 5/31/2000
Underwriter from whom Purchased:
Goldman Sachs & Co.
Affiliated Underwriters:
FleetBoston Robertson Stephens
Other Members of Syndicate:
Chase H & O
Banc of America Securities LLC
Aggregate dollar amount of purchase:
$1,125,000
Aggregate dollar amount of offering:
$200,000,000
Purchase price (net of fees and expenses):
$23.95
Date offering commenced:
5/31/2000
Commission: $1.05
4) Issuer: Cox Radio, Inc.
Date of Purchase: 6/21/2000
Underwriter from whom Purchased:
First Boston (Credit Suisse)
Affiliated Underwriters:
Fleet Securities
Other Members of Syndicate:
Salomon Smith Barney
Banc of America Securities LLC
Morgan Stanley Dean Witter
Allen & Company
First Union Securities
Aggregate dollar amount of purchase:
$7,250,000
Aggregate dollar amount of offering:
$232,000,000
Purchase price (net of fees and expenses):
$28.30
Date offering commenced:
6/21/2000
Commission: $0.70
