FIFTH THIRD FUNDS
                            38 Fountain Square Plaza
                              Cincinnati, OH 45263

November 26, 2008

VIA EDGAR

U.S. Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549

Re:  Fifth Third Funds - Post-Effective Amendment No. 68 to the
     Registration Statement on Form N-1A (File Nos. 33-24848; 811-5669)
     (the "Registration Statement")

Dear Sir or Madam:

Fifth Third Funds (the "Trust") hereby requests, pursuant to Rule 477 under the
Securities Act of 1933, as amended (the "Securities Act"), the withdrawal of
Post-Effective Amendment No. 68 under the Securities Act and Post-Effective
Amendment No. 69 under the Investment Company Act of 1940, as amended (the "1940
Act") to the Registration Statement, which was filed as EDGAR submission type
485APOS with the U.S. Securities and Exchange Commission on September 29, 2008
(Accession No. 0000891804-08-003106) (the "Post-Effective Amendment"). The
Post-Effective Amendment was filed in connection with the Trust's annual update
to its Registration Statement. Due to certain changes to the disclosure with
respect to certain series of the Trust, the Trust requests the withdrawal of the
Post-Effective Amendment. The Trust confirms that no securities were sold in
connection with the proposed offering pursuant to the Post-Effective Amendment.
The Trust anticipates filing a post-effective amendment to its Registration
Statement under Rule 485(b) under the Securities Act with respect to the series
of the Trust that were not affected by these disclosure changes on or about
November 28, 2008. In addition, the Trust anticipates filing a post-effective
amendment to its Registration Statement under Rule 485(a) under the Securities
Act with respect to the series of the Trust that were affected by these
disclosure changes in the near future, and intends to request acceleration of
the effectiveness of this post-effective amendment under Rule 485(a), pursuant
to Rule 461 under the Securities Act.

If you have any questions concerning the foregoing, please do not hesitate to
contact me at 513-534-6408, or Mary Constantino of Ropes & Gray LLP, counsel to
the Trust, at 617-951-7910.

Sincerely,

FIFTH THIRD FUNDS

By:  /s/ Matthew A. Swendiman
     ------------------------

Matthew A. Swendiman
Secretary