SecProbe.io

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                                   LAW OFFICES
                                SAMUEL KORNHAUSER
             155 Jackson Street, Suite 1807, San Francisco, CA 94111
                       (415) 981-6281; FAX (415) 981-7616
                            skornhauser@earthlink.net
SAMUEL KORNHAUSER

VIA EDGAR

                                 April 29, 2005

Kevin Rupert
United States Securities and Exchange Commission
450 Fifth Street, NW, Mail Stop 5-6
Washington, D.C. 20549

Re:  The  Navellier  Millennium  Funds  N1-A  Registration  No.'s  33-63155  and
     811-08995

Dear Mr. Rupert:
         In response to your April 22, 2005 telephone comments concerning the
Navellier Millennium Funds' ("the Fund") February 28, 2005 Rule 485A POS N1-A
filing, I on behalf of the Fund and its Board of Trustees respond as follows:

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

     2.   With  regard to the Fund now having  Navellier &  Associates,  Inc. as
          investment  adviser,  Navellier & Associates,  Inc. which is 99% owned
          and controlled by Louis Navellier,  was always providing the portfolio
          managers,  staff  analysts and all personnel for Navellier  Management
          Inc.  which is also 99% owned and controlled by Louis  Navellier.  For
          efficiency  and to reduce  duplicative  filing fees and  registrations
          Louis Navellier dissolved Navellier Management Inc. and the exact same
          portfolio  managers,  staff  analysts,  etc.  who had  been  providing
          investment  management for the Fund through Navellier  Management Inc.
          continued on in those exact same capacities performing the same duties
          for the fund through Navellier & Associates, Inc.

                  On December 15, 2004, I send a request for no action (if
          necessary) to Douglas Scheidt, Esq., explaining that pursuant to '40
          Act Rule 2a-6 and Wells Fargo, Prudential Insurance Co., Invesco and
          other no action letters, the Fund felt because there was no change in
          investment style, investment advisor, portfolio managers or personnel,
          no change in advisory fees or costs, etc. that the change should not
          be considered a change in investment advisor and that no shareholder
          approval under Section 15(a)(4) should be
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Kevin Rupert
April 29, 2005
Page 2

          required  since  there was in  reality  only a change in name,  not in
          advisors. The Commission responded after a review of my letter and the
          representation  that  there  was no change in the  actual  control  or
          management of the investment  advisor that in light of our reliance on
          Rule 2a-6 it did not appear that a no action letter was necessary. The
          change was made pursuant to Rule 2a-6.

     3.   With regard to your  comments,  we have made the changes you suggested
          i.e.,  we have noted that  excessive  trading  could have  adverse tax
          consequences  and  made  specific  that it  will  not be  allowed,  we
          clarified  the language  that the Fund does not  accommodate market
          timing,  we expanded  the  disclosure  of  portfolio  holdings section
          and broke it out into  public and  nonpublic  (ongoing  and ad hoc)
          disclosures and specified all persons who many have prior access to
          such  information and that they had duties not to disclose or trade on
          that   information.   We  also  expanded  the  portfolio   manager
          compensation   section  to  specify  all  forms  of  compensation  and
          incentive  percentages.  We  also  gave  more  detail  on the  factors
          considered  by the  Board of  Trustees  in  approving  the  investment
          advisory  agreement  and that the  disclosure  will go into the annual
          report.

                  We also made clear that the Fund is now a no load fund and
          that the former B and C shares are now no load A shares. In the
          performance table for the Top 20 Portfolio we eliminated one of the
          benchmark indexes, the Russell 3000 Index, and have only used the
          Russell 3000 Growth Index, we revised the hypothetical fees in the
          examples (1, 3, 5, 10 years) for both the Top 20 and International
          Growth portfolios and we gave a five-year history for portfolio
          manager Michael Garaventa.

          Thanks again for your assistance.

                                   Sincerely,

                                   Samuel Kornhauser

SK:kh

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