GODFREY & KAHN, S.C.
ATTORNEYS AT LAW
780 North Water Street
Milwaukee, Wisconsin 53202
Phone (414) 273-3500 Fax (414) 273-5198
December 27, 2000
VIA EDGAR
Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C. 20549
Re: STRONG OPPORTUNITY FUND, INC.
Ladies and Gentlemen:
We represent Strong Opportunity Fund, Inc. (the "Company"), in connection
with its filing of Post-Effective Amendment No. 23 (the "Post-Effective
Amendment") to the Company's Registration Statement (Registration Nos. 33-1932;
811-3793) on Form N-1A under the Securities Act of 1933 (the "Securities Act")
and the Investment Company Act of 1940. The Post-Effective Amendment is being
filed pursuant to Rule 485(b) under the Securities Act.
We have reviewed the Post-Effective Amendment and, in accordance with
Rule 485(b)(4) under the Securities Act, hereby represent that the
Post-Effective Amendment does not contain disclosures which would render it
ineligible to become effective pursuant to Rule 485(b).
We consent to the use of this letter in the Post-Effective Amendment.
Very truly yours,
GODFREY & KAHN, S.C.
/s/ Michelle M. Nelson
Michelle M. Nelson
MMN:ica
MW476598_1.DOC
