VAN KAMPEN COMSTOCK FUND
497J, 1999-05-03
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                    [Van Kampen Investments Inc. Letterhead]

                                                                       497(j)

                                  May 3, 1999

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

     Re: Van Kampen Comstock Fund
         Rule 497(j) Filing (File Nos. 2-27778 and 811-1570)

Ladies and Gentlemen:

     Van Kampen Comstock Fund (the "Registrant"), filed via EDGAR on April 29, 
1999, a copy of Post-Effective Amendment No. 52 to the Registration Statement 
on Form N-1A (the "Registration Statement") complete with exhibits filed 
therewith pursuant to Rule 485(b) of the General Rules and Regulations (the 
"1933 Act Rules") of the Securities and Exchange Commission promulgated under 
the Securities Act of 1933, as amended (the "Securities Act"), and under the 
Investment Company Act of 1940, as amended.

     In accordance with the provisions of Rule 497(j) of the 1933 Act Rules 
this letter serves to certify that the statement of additional information 
contained in the Registration Statement does not differ from that which would 
have been filed pursuant to Rule 497(c) of the Securities Act.

     Should the staff have any questions regarding the foregoing, please do not 
hesitate to call me at (630) 684-6774.


                                    Very truly yours,
                                    
                                    /s/ Nicholas Dalmaso
                                    
                                    Nicholas Dalmaso
                                    Assistant Secretary




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