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DORSEY & WHITNEY LLP
Advantus International Balanced Fund, Inc.
400 Robert Street North
St. Paul, Minnesota 55101
Ladies and Gentlemen:
We have acted as counsel to Advantus International Balanced Fund, Inc.,
a Minnesota corporation (the "Fund"), in connection with a Registration
Statement on Form N-1A (File No. 33-80756) (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 International Balanced 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
