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CHRISTOPHER D. CHRISTIAN
christopher.christian@dechert.com
+1 202 261 3321 Direct
+1 202 261 3333 Fax
November 22, 2006
U.S. Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Re: ING Equity Trust (on behalf of ING Fundamental Research Fund)
File No. 811-08817
Ladies and Gentlemen:
Attached for filing via the EDGAR system is Pre-effective Amendment No. 2
to the registration statement filed on on Form N-14 under the Securities Act
of 1933, as amended, ("Securities Act") for ING Equity Trust ("Registrant")
on October 11, 2006. The Registration Statement was filed in connection with
a reorganization in which ING Fundamental Research Fund, a series of the
Registrant, will acquire all of the assets of ING Disciplined LargeCap Fund,
another series of the Registrant, in exchange for shares of ING Fundamental
Research Fund and the assumption by ING Fundamental Research Fund of the
liabilities of ING Disciplined LargeCap Fund. Pre-Effective Amemdent No. 2 to
the Registration Statement is being filed to supplement the disclosure in the
Form N-14 in response to comments from the staff of Division of Investment
Management.
No fees are required in connection with this filing. Should you have any
questions please feel free to contact the undersigned at 202.261.3321 or Jeffrey
S. Puretz at 202.261.3358.
Sincerely,
/s/ Christopher D. Christian
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Christopher D. Christian
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