[Janus letterhead]

September 18, 2008

EDGAR Operations Branch
Securities and Exchange Commission
Division of Investment Management
100 F Street, NE
Washington, DC 20549-0505

Re: JANUS ADVISER SERIES (the "Registrant")
    1933 Act File No. 333-33978
    1940 Act File No. 811-09885

Dear Sir or Madam:

On behalf of the Registrant, enclosed please find definitive additional
materials filed on Schedule 14A relating to the definitive proxy statement filed
with the Securities and Exchange Commission on August 27, 2008.

No fee is required in connection with this filing pursuant to Rule 14a-6 under
the Securities Exchange Act of 1934.

If you have any questions regarding this filing, please call me at (303)
336-4045.

Sincerely,


/s/ Robin Nesbitt

Robin Nesbitt
Associate Counsel

Enclosure

cc: Stephanie Grauerholz-Lofton, Esq.
    Larry Greene, Esq.
    Cindy A. Antonson
    Donna Brungardt