[WM GROUP OF FUNDS LOGO] February 8, 2005 Securities and Exchange Commission 450 Fifth Street N.W. Washington, D.C. 20549 Re: WM Trust II (File Nos. 033-27489 and 811-05775) WM Variable Trust (File Nos. 033-57732 and 811-07462) Ladies and Gentlemen: We are filing today, through EDGAR, pursuant to Section 14(a) of the Securities Exchange Act of 1934, the following Preliminary Proxy Statements on Schedule 14A: - On behalf of WM Trust II, a Massachusetts business trust, and - On behalf of WM Variable Trust, a Massachusetts business trust. The Preliminary Proxy Statements are being filed for review related to special meetings of each of the above registrants for the purpose of approving or disapproving sub-advisory agreements on behalf of each registrant's Small Cap Growth Series. Please direct any questions concerning these filings to Brian McCabe, Esq. at (617) 951-7801 or to Justin Plouffe, Esq. at (617) 951-7551. Thank you. Very truly yours, /s/John T. West John T. West Enclosure Cc: Brian D. McCabe, Esq. Justin Plouffe, Esq.