[Frank Russell Investment Company letterhead]







March 8, 2004


VIA ELECTRONIC TRANSMISSION

U.S. Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, DC 20549

Re:   Frank Russell Investment Company
      File Nos.:  2-71299, 811-03153
      CIK No.:  0000351601

Ladies and Gentlemen:

On February 23, 2004 a 485APOS filing for Russell  Investment  Funds ("RIF") was
unintentionally  filed under the CIK number of Frank Russell  Investment Company
(Accession No.:  0000945621-04-000067)  (the "Filing").  The Filing was intended
for RIF, and a 485APOS was properly  filed for RIF, as intended,  following  the
discovery of the error.

Pursuant  to Rule 477 of the  Securities  Act of 1933,  as  amended,  we  hereby
request that the Securities and Exchange Commission consent to the withdrawal of
the Filing with respect to Frank Russell Investment  Company. No securities were
sold in connection with the Filing.

We apologize for any confusion this may have caused.  Please direct any comments
or questions  regarding this  withdrawal to John V. O'Hanlon at  617.728.7111 or
Colin J. Dean at 617.654.8624.


Very truly yours,


/s/ Mary Beth Rhoden
Mary Beth Rhoden
Assistant Secretary