[SRSY LOGO] Stradley Ronon Stevens & Young, LLP
2600 One Commerce Square
Philadelphia, PA 19103-7098
Telephone (215) 564-8000
Fax (215) 564-8120
Barbara A. Nugent
BNugent@stradley.com
215-564-8092
March 8, 2005
VIA EDGAR
Ms. Mary Cole
U.S. Securities and Exchange Commission
Division of Investment Management
450 Fifth Street, N.W.
Washington, D.C. 20549
RE: Gartmore Mutual Funds (formerly, Nationwide Mutual Fund)
("Registrant") SEC File Nos. 333-40455/811-08495; CIK No. 0001048702
Dear Ms. Cole:
We are writing on behalf of the above-referenced Registrant, pursuant to
Rule 477(a) under the Securities Act of 1933, as amended, to request the consent
of the U.S. Securities and Exchange Commission (the "Commission") to the
withdrawal of post-effective amendment ("PEA") No. 73, No. 74 to the
Registrant's registration statement on Form N-1A. Such filing was accepted via
EDGAR at 5:26 p.m. on February 28, 2005 (Accession No. 0000950116-05-000827).
Such PEA was filed in an unsuccessful attempt to incorporate by reference, the
Registrant's Statement of Additional Information, which had inadvertently been
omitted from the EDGAR filing of the Registrant's Post-Effective amendment that
was filed and "received" by EDGAR at 9:24 p.m. on Friday, February 25, 2005, but
not "accepted" by EDGAR until 8:57 a.m. on Monday, February 28, 2005 (Accession
No. 0000950116-05-000789).
Following our discussion with Ms. Sanders on Tuesday, March 1, 2005,
Registrant refiled its annual post-effective amendment to its registration
statement on Form N-1A in its entirety. This filing was accepted via EDGAR at
1:32 p.m. on Wednesday, March 2, 2005 (Accession No. 0000950116-05-000854). The
Registrant has informed us that no securities were sold in reliance on PEA No.
73, No. 74 and none will be.
Therefore, Registrant respectfully requests the Commission's consent to the
withdrawal of Registrant's PEA No. 73, No. 74 (Accession No.
0000950116-05-000827).
Philadelphia, PA o Malvern, PA o Wilmington, DE o Cherry Hill, NJ o Washington, DC
A Pennsylvania Limited Liability Partnership
Ms. Mary Cole
March 8, 2005
Page 2
If you have any questions, or require anything further regarding the
request, please contact me at (215) 564-8092, or in my absence, Allan Oster,
Esquire, Esquire, Assistant General Counsel, Gartmore Global Investments, Inc.
at (215) 530-1467.
Sincerely,
/s/Barbara A. Nugent
Barbara A. Nugent
cc: Allan Oster, Esquire
