[ING STATIONERY]
	May 2, 2011
	United States Securities and Exchange Commission
	100 F Street N.E., Room 1580
	Washington, DC 20549
	Re:		File Nos. 033-34370, 811-02512
			Prospectus Name: ING Marathon Plus
	Dear Commissioners:
	Please be advised that in lieu of filing a copy of the ING Marathon Plus Prospectus and
	Statement of Additional Information under Rule 497(c) of the Securities Act of 1933 (the “1933
	Act”) for certain group or individual deferred variable annuity contracts, we hereby certify the
	following pursuant to Rule 497(j) of the 1933 Act:
	(1	)	The form of the Prospectus and Statement of Additional Information that would have been
			filed under Rule 497(c) of the 1933 Act would not have differed from that contained in the
			most recent registration statement filed on April 21, 2011; and
	(2	)	The text of the most recent registration statement or amendment has been filed electronically.
	Please do not hesitate to contact me should you have any questions or comments.
	Sincerely,
	/s/ Nicholas Morinigo
	Nicholas Morinigo
	Counsel
	1475 Dunwoody Drive
	West Chester, PA 19380-1478
Tel:	610-425-3447
Fax:	610-425-3520