[Frank Russell Investment Company letterhead]



October 25, 2004


VIA EDGAR

U.S. Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, DC 20549

Re:   Frank Russell Investment Company
      File Nos.:  2-71299, 811-03153
      CIK No.:  0000351601

Ladies and Gentlemen:

On September  14, 2004, a 485APOS  filing for Frank Russell  Investment  Company
(the "Trust") was filed under Rule  485(a)(2) of the  Securities Act of 1933, as
amended,  adding  four new series to the Trust (the "First  Filing").  The First
Filing  is  labeled  as   Post-Effective   Amendment  No.  70  (Accession   No.:
0000950134-04-013664)  and was accepted as of September  15, 2004.  On September
15, 2004, a second  485APOS  filing for the Trust was filed under Rule 485(a)(2)
in order to supplement the first filing with additional information (the "Second
Filing").  The  Second  Filing is  labeled as  Post-Effective  Amendment  No. 71
(Accession No.:  0000950134-04-013718) and was also accepted as of September 15,
2004.

It was our intention  that the First Filing be superseded by the Second  Filing.
In order to ensure that the First  Filing does not become  effective  under Rule
485(a)(2),  we respectfully  request that pursuant to Rule 477 of the Securities
Act of 1933, as amended,  the Securities and Exchange  Commission consent to the
withdrawal of the First Filing.  No securities  were sold in connection with the
First Filing.

Please  direct any comments or questions  regarding  this  withdrawal to John V.
O'Hanlon at 617.728.7111 or Tiffany P. Gauthier at 617.654.8612.


Very truly yours,



/s/ Mary Beth Rhoden
Mary Beth Rhoden
Assistant Secretary