CGM CAPITAL DEVELOPMENT FUND
497J, 2000-05-01
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                               BINGHAM DANA LLP
                               150 FEDERAL STREET
                        BOSTON, MASSACHUSETTS 02110-1726

                                  May 1, 2000

VIA EDGAR

Securities and Exchange Commission
Division of Investment Management
Judiciary Plaza
450 Fifth Street, N.W.
Washington, D.C. 20549

   Re:   CGM Capital Development Fund
         Registration Statement on Form N-1A
         (File Nos. 2-16252 and 811-933)

Ladies and Gentlemen:

     Pursuant to Rule 497(j) under the Securities Act of 1933, as amended, CGM
Capital Development Fund, a Massachusetts business trust (the "Trust"), hereby
certifies that the forms of the Prospectus and Statement of Additional
Information that would have been filed by the Trust pursuant to Rule 497(c)
upon the effectiveness of Post-Effective Amendment Number 66 to the Trust's
registration statement on Form N-1A (the "Amendment") would not have differed
from those contained in the Amendment. The Amendment, which was filed via the
EDGAR system on April 25, 2000, is the most recent amendment to the Trust's
registration statement relating to the Trust.

     Please call the undersigned at (617) 951-8383 or Jeremiah J. Bresnahan,
Jr. at (617) 951-8724 or Thomas John Holton at (617) 951-8587, with any
questions relating to this letter.

                                            Sincerely,


                                            Jennifer H. Hurford




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