[Letterhead of State Street Research &
Management Company,
One Financial Center,
Boston, MA 02111]
December 22, 1999
Securities and Exchange Commission
450 Fifth Street N.W.
Judiciary Plaza
Washington, D.C. 20549
RE: State Street Research Capital Trust
Securities Act of 1933 File No. 2-86271
Investment Company Act of 1940 File No. 811-3838
CIK No. 0000727101
Dear Sir or Madam:
The undersigned, STATE STREET RESEARCH CAPITAL TRUST, a Massachusetts
business trust, (the "Registrant"), does hereby certify as follows:
(1) That the forms of prospectus and Statement of Additional Information
that would have been filed under paragraph (c) of Rule 497 of the
Securities Act of 1933, as amended (the "Securities Act"), would not
have differed from that contained in the most recent amendment to the
registration statement of the Registrant (Post-Effective Amendment No.
17 under the Securities Act; Amendment No. 23 under the Investment
Company Act of 1940) for the State Street Research Capital Fund a
series of the Registrant; and
(2) That the text of the most recent amendment to the registrant's
registration statement has been filed electronically (EDGAR accession
number 0000950146-99-001816).
STATE STREET RESEARCH
CAPITAL TRUST
By: /s/ Darman A. Wing
----------------------
Darman A. Wing
Assistant Secretary
cc: John Hunt, Esq.
Geoffrey R.T. Kenyon, Esq.
Evelyn M. Talmo
Goodwin, Procter & Hoar
