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VALIC Company I

787 Seventh Avenue

 New York, NY 10019-6099

 Tel: 212 728 8000

 Fax: 212 728 8111

 September 22, 2025

VIA EDGAR

 Kalkidan Ezra. Esq.

 Division of Investment Management

 Securities and Exchange
Commission

 100 F Street, NE

 Washington, D.C. 20549

 Re:

 Large Cap Core Fund (formerly, Large Capital Growth Fund), a series of VALIC Company I

Securities Act File No. 002-83631

Investment Company Act File No. 811-03738

 Dear Ms. Ezra:

On behalf of Large Cap Core Fund (formerly, Large Capital Growth Fund) (the “Fund), a series of VALIC Company I (the
“Registrant”), this letter responds to comments provided by the staff of the Division of Investment Management (the “Staff”) of the Securities and Exchange Commission (the “Commission”) on August 28, 2025,
regarding Post-Effective Amendment No. 123 to the Registrant’s Registration Statement on Form N-1A (the “Registration Statement”) under the Securities Act of 1933, as amended, and
Amendment No. 122 under the Investment Company Act of 1940, as amended, which was filed with the Commission on July 24, 2025.

The Staff’s comments, which are set forth below in italicized text, have been summarized to the best of our
understanding. We have discussed the Staff’s comments with representatives of the Registrant. The Registrant’s responses to the Staff’s comments are set out immediately under the restated comment. Please note that we have not
independently verified information provided by the Registrant. A Post-Effective Amendment to the Registration Statement (the “Amendment”), which reflects changes made in response to the Staff’s comments, along with changes made to
update certain other information in the Registration Statement, will be filed at a later date. Unless otherwise indicated, defined terms used herein have the meanings set forth in the Registration Statement.

* * * * * * * * * *

 Comment No. 1:

 The Staff reminds you that the Registrant and its management are responsible for the accuracy and adequacy of the
disclosures, notwithstanding any review, comments, action or absence of action by the Staff. Where a comment is made in one location and it is applicable to all similar disclosure appearing elsewhere in the Registration Statement, please ensure the
corresponding changes are made to all similar disclosure. Please fill in any bracketed language or any statements that are incomplete prior to going effective. Please provide your responses to Staff comments

BRUSSELS CHICAGO DALLAS FRANKFURT HAMBURG HOUSTON 
LONDON LOS ANGELES 

MILAN MUNICH NEW YORK PALO
ALTO PARIS ROME SAN FRANCISCO WASHINGTON

 on EDGAR at least five (5) business days in advance of the effective date, and please include as an exhibit to your
response letter either the marked document showing changes from the initial filing or, if appropriate, marked changed pages. Once the correspondence is filed, please provide notice by email.

 Response No.1:

 The Registrant acknowledges the Staff’s comments and will respond as requested.

 Comment No. 2:

 With respect to the subsection entitled “Fund Summary: Large Cap Core Fund (formerly, Large Capital Growth Fund)
– Fees and Expenses of the Fund,” please provide a completed fees and expenses table for the Staff’s review.

 Response No. 2:

 Please see Exhibit A attached hereto.

 Comment No. 3:

 With respect to the subsection entitled “Fund Summary: Large Cap Core Fund (formerly, Large Capital Growth Fund)
– Principal Risks of Investing in the Fund”:

 (a)   Please consider adding currency risk under this
subsection and in the section entitled “Investment Glossary.”

 (b)   The Staff notes that Growth Stock Risk and Securities
Lending Risk are included in the above-referenced subsection. Please consider also including them in the section entitled “Investment Glossary.”

 (c)   The Staff notes that “Emerging Markets
Risk” is included in the section entitled “Investment Glossary,” but it is not included in the above-referenced subsection. Please consider adding “Emerging Markets Risk” to the above-referenced subsection if investing
in emerging markets is part of the Fund’s principal investment strategy.

 Response No. 3:

 With respect to Comment No. 3(a), the Registrant respectfully declines to add currency risk to the above-referenced
subsection, as currency risk is not a principal investment risk of the Fund.

 With respect to Comment No. 3(b), the Registrant notes that the section entitled “Investment Glossary” contains
“Lending Fund Securities Risk” and “Growth Style Risk,” which correspond to “Securities Lending Risk” and “Growth Stock Risk,” respectively, in the above-referenced subsection. To ensure consistency in
terminology, the Registrant has revised the name “Lending Fund Securities Risk” in the “Investment Glossary” section to “Securities Lending Risk.” In addition, the Registrant has revised the name “Growth
Stock Risk” in the above-referenced subsection to “Growth Style Risk” to conform to the terminology utilized in the “Investment Glossary” section. The Registrant has also amended the disclosure regarding
“Growth

 2

 Style Risk” such that the discussion in Item 4 provides a summary of the risk, while the
disclosure in Item 9 contains a comprehensive description of the risk, in accordance with the requirements of Form N-1A. Please see Exhibit B attached hereto.

 With respect to Comment No. 3(c), the Registrant
respectfully declines to add “Emerging Markets Risk” to the above-referenced subsection, as investing in emerging markets is not a principal investment strategy of the Fund.

 Comment No. 4:

 In the subsection entitled “Fund Summary: Large Cap Core Fund (formerly, Large
Capital Growth Fund) – Principal Risks of Investing in the Fund – ESG Investment Risk,” please consider providing examples of the ESG criteria used by the portfolio managers.

 Response No. 4:

 The Registrant respectfully declines to revise the above-referenced risk factor. The
Registrant believes that any environmental, social, and governance (ESG) criteria considered by the portfolio managers are more appropriately addressed within the disclosure of the principal investment strategies section, rather than within the risk
factor section.

 Comment No. 5:

 With respect to the subsection entitled “Fund Summary: Large Cap Core Fund
(formerly, Large Capital Growth Fund) – Principal Risks of Investing in the Fund – Technology Sector Risk,” please consider making this risk factor a sub-risk of “Sector
Risk.”

 Response No. 5:

 The Registrant respectfully declines the request to designate “Technology Sector
Risk” as a sub-risk under “Sector Risk” in the above-referenced subsection. Instead, the Registrant has repositioned “Technology Sector Risk” to appear directly following
“Sector Risk” for organizational coherence. Please see Exhibit B attached hereto.

 Comment No. 6:

 With respect to the subsection entitled “Fund Summary: Large Cap Core Fund
(formerly, Large Capital Growth Fund) – Performance Information,” please supplementally provide the missing bar chart and the average annual total returns information that the Fund intends to include in the Amendment.

 Response No. 6:

 Please see Exhibit C attached hereto.

 * * * * * * * * * *

 3

 Please do not hesitate to contact me at (212)
728-3875 if you have comments or if you require additional information regarding the Fund.

 Respectfully submitted,

 /s/ Stacey P. Ruiz

 Stacey P. Ruiz

cc:
 Edward J. Gizzi, Esq., SunAmerica Asset Management, LLC

 
 Jennifer Rogers, Esq., SunAmerica Asset Management, LLC

 
 Elliot J. Gluck, Esq., Willkie Farr & Gallagher LLP

 4

 EXHIBIT A

Fees and Expenses of the Fund

This table describes the fees and expenses that you may pay if you buy, hold and sell shares of the Fund. The table and the example below do
not reflect the separate account fees charged in the variable annuity or variable life insurance policy (“Variable Contracts”) in which the Fund is offered. If separate account fees were shown, the Fund’s annual operating
expenses would be higher. Please see your Variable Contract prospectus for more details on the separate account fees.

 Annual Fund
Operating Expenses (expenses that you pay each year as a percentage of the value of your investment)

 Management Fees

0.64
%

 Other Expenses

0.11
%

 Total Annual Fund Operating Expenses

0.75
%

 Fee Waivers and/or Expense Reimbursements1

0.09
%

 Total Annual Fund Operating Expenses After Fee Waivers and/or Expense Reimbursements1

0.66
%

1
 The Fund’s investment adviser, The Variable Annuity Life Insurance Company (“VALIC”), has
contractually agreed to waive its advisory fee until September 30, 2026, so that the advisory fee payable by the Fund to VALIC equals 0.55% on the first $750 million of the Fund’s average daily net assets and 0.50% on average daily
net assets over $750 million. This agreement may be modified or discontinued prior to such time only with the approval of the Board of Directors of VALIC Company I (“VC I”), including a majority of the directors who are not
“interested persons” of VC I as defined in the Investment Company Act of 1940, as amended (the “1940 Act”).

Expense Example

 This
Example is intended to help you compare the cost of investing in the Fund with the cost of investing in other mutual funds. The Example assumes that you invest $10,000 in the Fund for the time periods indicated and then redeem or hold all of your
shares at the end of those periods. The Example also assumes that your investment has a 5% return each year and that the Fund’s operating expenses remain the same (except that the Example incorporates any applicable fee waiver and/or expense
limitation arrangements for only the first year). The Example does not reflect charges imposed by the Variable Contract. If the Variable Contract fees were reflected, the expenses would be higher. See the Variable Contract prospectus for information
on such charges. Although your actual costs may be higher or lower, based on these assumptions and the net expenses shown in the fee table, your costs would be:

 1 Year

 3 Years

 5 Years

 10 Years

$67

$231

$408

$922

 A-1

 Portfolio Turnover

The Fund pays transaction costs, such as commissions, when it buys and sells securities (or “turns over” its portfolio). These
costs, which are not reflected in annual fund operating expenses or in the Example, affect the Fund’s performance.

 During the most
recent fiscal year, the Fund’s portfolio turnover rate was 18% of the average value of its portfolio.

 A-2

 EXHIBIT B

 Equity Securities Risk. The Fund invests primarily in equity securities and is therefore
subject to the risk that stock prices will fall and may underperform other asset classes. Individual stock prices fluctuate from day-today and may decline significantly. The prices of individual stocks may be
negatively affected by poor company results or other factors affecting individual prices, as well as industry and/or economic trends and developments affecting industries or the securities market as a whole.

Large-Cap Companies Risk. Investing primarily in
large-cap companies carries the risk that due to current market conditions these companies may be unable to respond quickly to new competitive challenges or attain the high growth rate of successful smaller
companies. Larger, more established companies may be unable to respond quickly to new competitive challenges, such as changes in technology and consumer tastes. Larger companies also may not be able to attain the high growth rate of successful
smaller companies, particularly during extended periods of economic expansion.

 Management Risk. The investment style or strategy
used by a subadviser may fail to produce the intended result. A subadviser’s assessment of a particular security or company may prove incorrect, resulting in losses or underperformance.

Dividend-paying Stocks Risk. There is no guarantee that the issuers of the stocks held by the Fund will declare dividends in the future
or that, if dividends are declared, they will remain at their current levels or increase over time. Dividend-paying stocks may not participate in a broad market advance to the same degree as other stocks, and a sharp rise in interest rates or
economic downturn could cause a company to unexpectedly reduce or eliminate its dividend.

 Depositary Receipts Risk. Depositary
receipts are generally subject to the same risks as the foreign securities that they evidence or into which they may be converted. The issuers of unsponsored depositary receipts are not obligated to disclose information that is considered material
in the United States. Therefore, there may be less information available regarding the issuers and there may not be a correlation between such information and the market value of the depositary receipts. Certain depositary receipts are not listed on
an exchange and therefore are subject to illiquidity risk.

 Derivatives Risk. The prices of derivatives may move in unexpected ways
due to the use of leverage and other factors and may result in increased volatility or

losses. The Fund may not be able to terminate or sell derivative positions, and a liquid secondary market may not always exist for derivative positions.

Futures Risk. A futures contract is considered a derivative because it derives its value from the price of the underlying currency,
security or financial index. The prices of futures contracts can be volatile and futures contracts may lack liquidity. In addition, there may be imperfect or even negative correlation between the price of a futures contract and the price of the
underlying currency, security or financial index.

 ESG Investment Risk. The portfolio manager(s) may utilize ESG criteria,
integrate ESG considerations and/or use related analyses to select investments for the Fund. These strategies may impact the Fund’s performance, including relative to similar funds that do not adhere to such ESG criteria, ESG integration
and/or related analyses as part of the investment process. Additionally, the Fund’s adherence to these strategies in connection with identifying and selecting investments may require subjective and qualitative analysis and may be more
difficult if data about a particular company or market is limited, such as with respect to issuers in emerging markets countries. The Fund may invest in companies that do not reflect the beliefs and values of any particular investor. Socially
responsible norms differ by country and region, and a company’s ESG practices or a portfolio manager’s assessment of such may change over time. ESG characteristics may not be the only factors considered in selecting investments and as a
result, the Fund’s investments may not have favorable ESG characteristics or high ESG ratings.

 Foreign Investment Risk.
Investment in foreign securities involves risks due to several factors, such as illiquidity, the lack of public information, changes in the exchange rates between foreign currencies and the U.S. dollar, unfavorable political, social and legal
developments, or economic and financial instability. Foreign companies are not subject to the U.S. accounting and financial reporting standards and may have riskier settlement procedures. U.S. investments that are denominated in foreign currencies
or that are traded in foreign markets, or securities of U.S. companies that have significant foreign operations may be subject to foreign investment risk.

Growth Stock Risk. A “Growth” philosophy
is a strategy of investing in securities believed to offer the potential for capital appreciation. It focuses on securities of companies that are considered to have a historical record of above-average growth rate, significant growth potential,
above-average earnings

 B-1

 growth or
value, the ability to sustain earnings growth, or that offer proven or unusual products or services, or operate
in industries experienci