1933 Act/Correspondence

                                        January 3, 2005


VIA EDGAR

Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C. 20549

RE:      Phoenix Investment Trust 97
         File No. 333-34537
         Post-Effective Amendment No. 18

To the Commission Staff:

On December 9, 2004, Phoenix Investment Trust 97 filed a Post-Effective
Amendment to its Registration Statement on Form N-1A, the purpose of which was
supply for SEC review all disclosures required under recent rulemaking and to
make certain other changes of a non-material nature. This letter is in response
to comments received on December 30, 2004 to our proposed response to the
original comments received on said amendment filing from our examiner, Brion
Thompson.

1.   SAI, Disclosure of Fund Holdings. Our examiner requested that we respond
     more fully to Item 11(f)(1)(vi) by providing information regarding the
     procedures used to determine that disclosure of portfolio holdings is in
     the best interest of shareholders. We have revised the second paragraph of
     this section to include the requested information.
2.   SAI, Disclosure of Fund Holdings. Our examiner requested that we provide
     disclosure to clarify that the fund may enter into ongoing arrangements
     whereby public information is provided directly to third-parties, such as
     rating agencies, in addition to those listed and to indicate the frequency
     and the length of lag under any such arrangements. We have revised the
     paragraph under the subheading entitled "Public Disclosure" to reflect this
     information.

We believe the revised version of the Disclosure of Fund Holdings discussion is
now fully responsive to the SEC's comments, as well as to the requirements of
Item 11(f) of Form N-1A.

Please contact Ann Spooner at (860) 403-6753 or the undersigned at
(860)403-5246 if you have any questions concerning this matter.

                                        Very truly yours,



                                        /s/ Matthew A. Swendiman
                                        Matthew A. Swendiman