STRATUS FUND INC
497J, 1999-11-03
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                               STRATUS FUND, INC.

                      Certification Pursuant to Rule 497(j)


1933 Act Registration No. 33-37928
1940 Act Registration No. 811-6259

        The undersigned, being a duly elected officer of Stratus Fund, Inc. (the
"Company"),  pursuant  to Rule 497(j)  under the  Securities  Act of 1933,  does
hereby certify, with respect to Post-Effective Amendment No. 19 (the"Amendment")
to the Company's Registration Statement on Form N-1A, that:

        1.  The text of the Amendment was filed electronically with the
Securities and Exchange Commission on October 29, 1999; and

        2. The form of the Prospectuses and Statement of Additional  Information
that would have been filed by the Company  pursuant to Rule 497(c) in respect of
the  Amendment  would not have  differed  from those  contained in the Amendment
filed electronically as described above.

        IN WITNESS  WHEREOF,  the  undersigned  has executed this  Certification
Pursuant to Rule 497(j) on this 3rd day of November, 1999.

                                          STRATUS FUND, INC.



                                          By: /S/ Michael S. Dunlap
                                            ------------------------------
                                              Michael S. Dunlap, President



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