[ING FUNDS LOGO]

September 7, 2007

VIA EDGAR

U.S. Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

Re: Withdrawal of Registration Statement on Form N-14 of ING Equity Trust (on behalf of ING Opportunistic LargeCap Fund) (File Nos. 333-144966; 811-08817)

Ladies and Gentlemen:

In accordance with Rule 477 under the Securities Act of 1933, as amended, ING Equity Trust (the “Registrant”) hereby respectfully requests the U.S.  Securities and Exchange Commission  (the “Commission”) consent to the withdrawal of its Registration Statement on Form N-14, as filed with the Commission via EDGAR (File Nos. 333-144966; 811-08817) (the “Registration Statement”).

The Registration Statement was filed in connection with a reorganization in which ING Opportunistic LargeCap Fund, a series of the Registrant, will acquire all of the assets of ING Growth Fund, a series of ING Series Fund, Inc., in exchange for shares of ING Opportunistic LargeCap Fund and the assumption by ING Opportunistic LargeCap Fund of the known liabilities of ING Growth Fund.

This request to withdraw the Registration Statement is being made after consultation with the Commission Staff regarding the need to provide the identifier numbers of the classes of ING Opportunistic LargeCap Fund in the EDGAR submission of the Registration Statement pursuant to Rule 313 of Regulation S-T.

The Registrant confirms that no securities have been sold in connection with the offering and no prospectus contained in the Registration Statement has been distributed.  It is our opinion the withdrawal of this Registration Statement would be consistent with the public interest and the protection of investors.

Accordingly, we request that an order granting the withdrawal of this Registration Statement be deemed granted by the Commission immediately.

We appreciate your prompt attention to this matter.

Should you have any questions, please feel free to contact the undersigned at 480.477.2666 or Steven S. Drachman of Dechert LLP at 212.641.5627.

Sincerely,

/s/ Huey P. Falgout

Huey P. Falgout, Jr.

Secretary

cc:	Christopher C. Okoroegbe, Esq.
	ING U.S. Legal Services
	Philip H. Newman, Esq.
	Goodwin Procter, LLP
	Jeffrey S. Puretz, Esq.
	Dechert LLP