THOMPSON     ATLANTA        CINCINNATI            COLUMBUS               NEWYORK
HINE        BRUSSELS          CLEVELAND          DAYTON         WASHINGTON, D.C.
----------------------------------------


                                                                  April 24, 2008
VIA EDGAR (CORRESPONDENCE FILING)

U.S. Securities and Exchange Commission
100 F Street, N.E.
Washington, DC  20549
Attn: Mr. Bric Barrientos, Senior Counsel
(202) 551-6946

RE:     PC&J Preservation Fund (the "Registrant")
File Nos. 2-95285; 811-4204
---------------------------

Dear Mr. Barrientos:

     On  behalf  of  the  Registrant,  this  letter responds to the comments you
provided  by telephone to fund counsel, with respect to Post-Effective Amendment
No. 27 to the Registration Statement, filed February 29, 2008 (the "Amendment").
Your  comments  are  set  forth  below, and each is followed by the Registrant's
response.

COMMENT  1:
     The Registrant is advised to include correct page numbers in any subsequent
filing.  With  regard  to  the  section of the prospectus entitled "What are the
Main  Risks  of Investing in the Fund?", disclose whether the Fund will have any
expose  to  sub-prime mortgage securities and if so, disclose the specific risks
associated  with  the  Fund's  investment  in  such  securities.

RESPONSE:
     The  Registrant  will  include  correct  page  numbers  in  future filings.
Additionally,  the  adviser has confirmed that the Fund does not invest directly
in  any  sub-prime  mortgage securities, and is unaware of any material indirect
exposure.

COMMENT  2:
     With  regard  to  the  fifth  paragraph in the section entitled "Additional
Information on Investment Objective, Policies and Risks" in the prospectus, when
discussing  the Fund's ability to take temporary defensive positions, include in
the  disclosure  required  by  Instruction  6  of  Item  4  of  Form  N-1A.

RESPONSE:
     The fifth paragraph has been revised as follows:

     "The Fund may, from time to time, take temporary defensive positions that
are inconsistent with the Fund's principal investment strategies in attempting
to respond to adverse market, economic, political, or other conditions. The Fund
may invest for these

purposes in money market instruments (including money
market funds), U.S. Treasury bills or other short-term interest bearing
securities and in bank interest bearing checking accounts, including interest
bearing checking accounts of the custodian.  If the Fund invests in a money
market fund, the shareholders of the Fund generally will be subject to
duplicative management fees.  The Fund may also invest in such short-term
instruments at any time to maintain liquidity or pending selection of
investments in accordance with its policies. To the extent that the Fund takes
such temporary defensive measures, there can be no assurance that the Fund's
investment objective will be obtained.

COMMENT  3:     In  the  Statement  of Additional Information, under the heading
"Investment  Objective  and  Policies  -  Fundamental,"  item  number  7
"Concentration,"  the  second sentence seems to contain several misplaced words.

RESPONSE:
       This appears to be an error created in the EDGAR conversion.  The
      Registrant has corrected the second sentence of the section to read:

   "This limitation is not applicable to investment in obligations issued or
    guaranteed by the U.S. government, its agencies and instrumentalities or
                  repurchase agreements with respect thereto."

COMMENT  4:
     With  regard  to the section entitled "Disclosure of Portfolio Holdings" in
the  statement  of  additional information, please provide additional disclosure
regarding  the period of time between the assimilation of the portfolio holdings
information and disclosure to those service providers and entities identified as
having  access  to  portfolio  holdings  information.

RESPONSE:
     In response to the comment, the Registrant has added the following as a new
fourth  sentence  to  the  second  paragraph  of  the  "Disclosure  of Portfolio
Holdings"  section:

     "This  daily  release  of  portfolio  holdings  information  is  done
contemporaneously  with  the  gathering of the information and there is no delay
period  before  its  dissemination."



The  Registrant  has  authorized  us  to  acknowledge  on  its  behalf  that:

-     The  Registrant  is  responsible  for  the  adequacy  and  accuracy of the
disclosure  in  the  filings;
-     Staff comments or changes to disclosure in response to staff comments in
the filings reviewed by the staff do not foreclose the Securities and Exchange
Commission from taking any action with respect to the filing; and
-     The Registrant may not assert staff comments as a defense in any
proceeding initiated by the Securities and Exchange Commission or any person
under the federal securities laws of the United States.

Please  contact  me  at  (513)  352-6725  if  you  should  require  any  further
information.

Sincerely,



/s/ Thompson Hine LLP

Thompson Hine LLP