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<TYPE>LETTER
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<FILENAME>upload.txt
<DESCRIPTION>COMMENT LETTER
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Mail Stop 0505					        September 23, 2004

David C. Phelan, Esq.
Wilmer Cutler Pickering Hale and Dorr LLP
60 State Street
Boston, MA  02109

Re:	Pioneer Equity Opportunity Fund (the "Fund")
	Registration Statement on Form N-1A
	Registration Numbers 333-118562; 811-21623
	Filed August 25, 2004

Dear Mr. Phelan:

We have reviewed the registration statement referenced above and
have
the following comments.  Pursuant to Release No. 33-6510 and in
reliance upon the representations contained in your transmittal
letter, we performed a limited review of the registration
statement.

Registration Statement

Prospectus

Investment Objectives

Indicate whether the Fund`s investment objectives may be changed
without notice to shareholders.

Principal Investment Strategies

Clarify that the Fund will invest at least 80% of its net assets,
plus the amount of any borrowings for investment purposes, in
equity
securities.

State whether the Fund may change its policy to invest at least
80%
of its assets in equity securities upon giving shareholders at
least
60 days prior notice of the change in that policy.

Disclose how convertible debt will it be treated for purposes of
determining compliance with the Fund`s investment restrictions.

Fees and Expenses

Refer to the third sentence of footnote (3).  Insert the phrase
"within three years of being incurred" after the word
"reimbursement."

Management Fee

The fee table indicates that the management fee is 0.75% of the
Funds
average daily net assets, yet the discussion appearing under
"Management Fee" states that the amount of the management fee is
0.70%.  Please reconcile.

Net Asset Value

The second sentence of the third paragraph states that the values
provided by a pricing service may be based upon "securities
expected
to trade in a similar manner."  Please clarify that this is a
method
of determining fair value as made in good faith by the Fund`s
board
of trustees.

Visit our Website

Clarify that the "shareowner reports," referenced in the second
paragraph, will become available only after the Fund has an
operating
history.

Statement of Additional Information

Fund History

Reconcile the statement that the Fund is non-diversified with the
Fund`s sixth enumerated fundamental investment restriction.  If
the
Fund is, in fact, non-diversified, then expand the "Principal
Risks
of Investing in the Fund" section of the prospectus to describe
the
principal risks of being a non-diversified fund.

Risks of Non-U.S. Investments

Supplementally explain why the "Risks of Non-U.S. Investments"
section discussions regarding "Currency Risks," "Custodian
Services
and Related Investment Cost," and "Withholding and Other Taxes"
that
appear in other Pioneer funds` SAIs are not included in the Fund`s
SAI.

Fundamental Investment Restrictions

Revise the eighth enumerated investment restriction to indicate
that
the Fund "will" rely upon available industry classifications and
identify the industry classifications upon which it will rely.

Non-Fundamental Investment Restrictions

Expand the last paragraph to describe briefly, in plain English,
the
significance of the Investment Company Act of 1940 provisions
cited.

Tax Status

Describe the extent to which dividends distributed by REITs
qualify
for "the maximum 15% U.S. federal income tax rate on qualified
dividend income."

Closing

We note that portions of the filing are incomplete.  We may have
additional comments on such portions when you complete them in a
pre-
effective amendment, on disclosures made in response to this
letter,
on information supplied supplementally, or on exhibits added in
any
pre-effective amendments.

Whenever a comment is made in one location, it is considered
applicable to all similar disclosure appearing elsewhere in the
registration statement.

Response to this letter should be in the form of a pre-effective
amendment filed pursuant to Rule 472 under the Securities Act.
Where
no change will be made in the filing in response to a comment,
please
indicate this fact in a supplemental letter and briefly state the
basis for your position.

Please advise us if you have submitted or expect to submit an
exemptive application or no-action request in connection with your
registration statement.

You should review and comply with all applicable requirements of
the
federal securities laws in connection with the preparation and
distribution of a preliminary prospectus.

We urge all persons who are responsible for the accuracy and
adequacy
of the disclosure in the filings reviewed by the staff to be
certain
that they have provided all information investors require for an
informed decision.  Since the Fund and its management are in
possession of all facts relating to the Fund`s disclosure, they
are
responsible for the accuracy and adequacy of the disclosures they
have made.

Notwithstanding our comments, in the event the Fund requests
acceleration of the effective date of the pending registration
statement, it should furnish a letter, at the time of such
request,
acknowledging that

* should the Commission or the staff, acting pursuant to delegated
authority, declare the filing effective, it does not foreclose the
Commission from taking any action with respect to the filing;
* the action of the Commission or the staff, acting pursuant to
delegated authority, in declaring the filing effective, does not
relieve the Fund from its full responsibility for the adequacy and
accuracy of the disclosure in the filing; and
* the Fund may not assert this action as a defense in any
proceeding
initiated by the Commission or any person under the federal
securities laws of the United States.

In addition, please be advised that the Division of Enforcement
has
access to all information you provide to the staff of the Division
of
Investment Management in connection with our review of your filing
or
in response to our comments on your filing.

We will consider a written request for acceleration of the
effective
date of the registration statement as confirmation of the fact
that
those requesting acceleration are aware of their respective
responsibilities.  We will act on the request and, pursuant to
delegated authority, grant acceleration of the effective date.

Should you have any questions regarding this letter, please
contact
me at (202) 942-0627.

						Sincerely,

						Dominic Minore
						Attorney

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Mr. David C. Phelan, Esq.
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