WITTER DEAN S&P 500 INDEX FUND
497J, 1997-09-03
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                 DEAN WITTER S&P 500 INDEX FUND 
                     TWO WORLD TRADE CENTER
                    NEW YORK, NEW YORK 10048
 

                                   September 3, 1997


Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C.  20549

Re:  Dean Witter S&P 500 Index Fund
     File Nos. 333-29721 and 811-08265
     Rule 497(j) Filing         

Dear Sir/Madam:

     On behalf of the Registrant, the undersigned certifies that
the form of Prospectus and Statement of Additional Information that
would have been filed under Section 497(c) would not have differed
from those contained in the text of the Registrant's most recent
registration statement that was filed electronically via EDGAR with
the Securities and Exchange Commission on July 30, 1997.


                                   Very truly yours,
                               /s/ Carsten Otto
                                   Carsten Otto
                                   Assistant Secretary
                                   


cc: Barry Fink    
    Randolph Koch

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