DYKEMA GOSSETT PLLC
400 Renaissance Center
Detroit, MI 48243
VIA EDGAR
November 3, 1998
U.S. Securities and Exchange Commission
Judiciary Plaza
450 Fifth Street, N.W.
Washington, D.C. 20549
Re: Fifth Third Funds (the "Registrant")
No. 33-24848
No. 811-5669
Dear Sir or Madam:
As counsel to the Registrant, we are writing to certify that the forms of
Prospectuses and the Combined Statements of Additional Information dated
November 2, 1998, that would have been filed under paragraph (b) or (c) of
Rule 497 under the Securities Act of 1933 by the above-referenced Registrant
would not have differed from that contained in the most recent Post-
Effective Amendment to the Registration Statement on Form N-1A, which was
electronically filed on behalf of the Registrant on October 30, 1998.
Please contact the undersigned at 313-568-6973 if you have any questions.
Sincerely,
DYKEMA GOSSETT PLLC
/S/ Paul R. Rentenbach
Paul R. Rentenbach