AXP VARIABLE PORTFOLIO MANAGED FUND INC
497J, 2000-11-01
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November 1, 2000



Securities and Exchange Commission
450 Fifth St. N.W., Mail Stop 5-6
ATTN: Zandra Y. Bailes, Document Control - EDGAR
Washington, D.C.  20549-1004

Re:    AXP Variable Portfolio - Managed Series, Inc.
          AXP Variable Portfolio - Diversified Equity Income Fund
          AXP Variable Portfolio - Managed Fund

       Post-Effective Amendment No. 28
       File No. 2-96367/811-4252

Dear Ms. Bailes:

Registrant  certifies  that the form of  prospectus  and Statement of Additional
Information that would have been filed under paragraph (c) of Rule 497 would not
have differed from that contained in the most recent  Registration  Statement or
Amendment,  and the text of the most recent Registration  Statement or Amendment
has been filed electronically.

Sincerely,

AXP VARIABLE PORTFOLIO - MANAGED SERIES, INC.
    AXP Variable Portfolio - Diversified Equity Income Fund
    AXP Variable Portfolio - Managed Fund




/s/ Leslie L. Ogg
    Leslie L. Ogg
    Vice President

LLO/CLGE/ps



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