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Law Offices
DRINKER BIDDLE & REATH LLP
Philadelphia National Bank Building
1345 Chestnut Street
Philadelphia, PA 19107-3496
Telephone: (215) 988-2700
Fax: (215) 988-2757
March 1, 1999
VIA EDGAR TRANSMISSION
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Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, DC 20549
Re: The Commerce Funds, Inc.
Registration No. 33-80966/811-8598
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Ladies and Gentlemen:
On behalf of The Commerce Funds (the "Trust") and pursuant to Rule
497(j) under the Securities Act of 1933, as amended (the "1933 Act"), I hereby
certify that: (i) the form of Prospectuses and Statement of Additional
Information dated March 1, 1999 for the Trust that would have been filed under
paragraph (c) of Rule 497 under the 1933 Act would not have differed from the
Prospectuses and Statement of Additional Information contained in the Trust's
most recent Post-Effective Amendment to its Registration Statement on Form N-1A
under the 1933 Act and the Investment Company Act of 1940, as amended, ("PEA #
9"), which was filed on February 24, 1999; and (ii) the text of PEA #9 has been
filed electronically.
Sincerely,
/s/ Diana E. McCarthy
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Diana E. McCarthy
