Exhibit 11

                                [Form of Opinion]
                                   Dechert LLP
                               1775 I Street, N.W.
                             Washington, D.C. 20006

July 24, 2003


Board of Directors
ING Investment Funds, Inc.
7337 E. Doubletree Ranch Road
Scottsdale, AZ 85258-2034

Re:      ING Investment Funds, Inc., on behalf of ING MagnaCap Fund

Dear Ladies and Gentlemen:

We have acted as counsel to ING Investment Funds, Inc., a Maryland corporation
(the "Company"), and we have a general familiarity with the Company's business
operations, practices and procedures. You have asked for our opinion regarding
the issuance of shares of common stock by the Company in connection with the
acquisition by ING MagnaCap Fund, a series of the Company, of the assets of ING
Large Company Value Fund, a series of ING Equity Trust, which will be registered
on a Form N-14 Registration Statement (the "Registration Statement") to be filed
by the Company with the U.S. Securities and Exchange Commission.

We have examined originals or certified copies, or copies otherwise identified
to our satisfaction as being true copies, of various corporate records of the
Company and such other instruments, documents and records as we have deemed
necessary in order to render this opinion. We have assumed the genuineness of
all signatures, the authenticity of all documents examined by us and the
correctness of all statements of fact contained in those documents.

On the basis of the foregoing, it is our opinion that the shares of common stock
of the Company being registered under the Securities Act of 1933, as amended, in
the Registration Statement have been duly authorized and will be legally and
validly issued, fully paid and non-assessable upon transfer of the assets of ING
Large Company Value Fund pursuant to the terms of the Agreement and Plan of
Reorganization included in this Registration Statement.

We hereby consent to use of this opinion as an exhibit to the Registration
Statement and to all references to our firm therein.

Very truly yours,