[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 supplement dated April 29, 2011 for the
	ING Marathon Plus Prospectus 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 supplement to the Prospectus 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 28, 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