PRUDENT BEAR FUNDS INC
497J, 1998-12-09
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                                                                December 7, 1998


VIA EDGAR SYSTEM

Securities and Exchange Commission
450 Fifth Street, N.W.
Judiciary Plaza
Washington, DC  20549

           Re:  Prudent Bear Funds, Inc.
                File Nos. 33-98726 and 811-09120
                Rule 497(j) Certification

Ladies & Gentlemen:

          The  undersigned  officer of Prudent Bear Funds,  Inc. (the "Company")
does hereby certify pursuant to Rule 497(j) promulgated under the Securities Act
of 1933, as amended:

          1. that the form of prospectus and statement of additional information
that would have been filed under paragraph (c) of Rule 497 promulgated under the
Securities Act of 1933, as amended,  would not have differed from that contained
in Post-Effective  Amendment No. 5 to Form N-1A Registration  Statement filed by
the Company on November  30,  1998,  which is the most recent  amendment to such
registration statement; and

          2. that the text of Post-Effective  Amendment No. 5 was filed with the
Securities  and  Exchange  Commission  by direct  transmittal  through the EDGAR
system on November 30, 1998.

                                  Very truly yours,

                                  PRUDENT BEAR FUNDS, INC.



                                  By:      /s/  David W. Tice
                                           David W. Tice
                                           President


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