[ING STATIONERY]

December 20, 2010

United States Securities and Exchange Commission
100 F Street N.E., Room 1580
Washington, DC 20549

Re:	File Nos. 333-63692, 811-05626
	Prospectus Name: ING SmartDesign Advantage

Dear Commissioners:

Please be advised that in lieu of filing a copy of the ING SmartDesign Advantage Prospectus
and Statement of Additional Information under Rule 497(c) of the Securities Act of 1933 (the
“1933 Act”) for certain deferred combination variable and fixed 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 or amendment; 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

ING USA Annuity and Life Insurance Company
1475 Dunwoody Drive
West Chester, PA 19380-1478

Tel: (610) 425-3447 

Fax: (610) 425-3520