SecProbe.io

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December 14, 2004

VIA EDGAR (Correspondence Filing)

Ms. Patsy Mengiste
Securities and Exchange Commission
450 Fifth Street, N.W.  (Mail Stop 05-05)
Washington, D.C. 20549-5005

ATTN:    Document Control - EDGAR

RE:      AXP Global Series, inc. (File Nos. 811-5696/33-25824, PEA# 42)
                  AXP Global Bond Fund
                  AXP Global Technology Fund
                  AXP Threadneedle Emerging Markets Fund
                  AXP Threadneedle Global Balanced Fund
                  AXP Threadneedle Global Equity Fund

         AXP International Series, Inc. (File Nos. 811-4075/2-92309, PEA# 40)
                  AXP Threadneedle European Equity Fund
                  AXP Threadneedle International Fund

         AXP Partners International Series, Inc. (File Nos. 811-10427/333-64010,
         PEA# 10)
                  AXP Partners International Aggressive Growth Fund
                  AXP Partners International Core Fund
                  AXP Partners International Select Value Fund
                  AXP Partners International Small Cap Fund

Dear Ms. Mengiste:

This letter is in response to Staff's oral comments that you  communicated to us
by telephone on or about December 9, 2004.  The language also reflects  comments
from counsel for the funds referenced above.

                                   PROSPECTUS

APPLICABLE TO ALL FUNDS

COMMENT 1: Under the "Exchanging/Selling Shares" section, with respect to your
market timing disclosure, you need to state that "to the extent the fund invests
in certain securities" (i.e. a global/international fund has significant foreign
holdings) and in addition based on the level of holdings in a certain type of
security, add a statement to address the fact that the risk would be greater.
<PAGE>

RESPONSE: For each of the funds listed below, we have amended the second
paragraph under "Exchanges/Selling Shares" to read as follows (changes are
underlined): [Please see attachment A for the full disclosure, including
language that was removed].

APPLICABLE TO AXP GLOBAL BOND, AXP GLOBAL TECHNOLOGY, AXP THREADNEEDLE GLOBAL
BALANCED, AXP THREADNEEDLE GLOBAL EQUITY, AXP THREADNEEDLE EUROPEAN EQUITY, AXP
THREADNEEDLE INTERNATIONAL, AXP PARTNERS INTERNATIONAL AGGRESSIVE GROWTH, AXP
PARTNERS INTERNATIONAL CORE, AND AXP PARTNERS INTERNATIONAL SELECT VALUE ONLY:

Funds that INVEST IN SECURITIES WHICH trade on overseas securities markets may
be vulnerable to market timers who seek to take advantage of changes in the
values of securities between the close of overseas markets and the close of U.S.
markets, which is generally the time at which a fund's NAV is calculated. TO THE
EXTENT THAT THE FUND HAS SIGNIFICANT HOLDINGS OF FOREIGN SECURITIES, the risks
of market timing may be greater THAN FOR FUNDS THAT DO NOT HAVE SIGNIFICANT
FOREIGN HOLDINGS. See "Principal Investment Strategies" for a discussion of THE
KINDS OF SECURITIES IN WHICH THE FUND INVESTS. See also "Valuing Fund Shares"
for a discussion of the Fund's policy on fair value pricing, which is intended,
in part, to reduce the frequency and effect of market timing.

APPLICABLE TO AXP THREADNEEDLE EMERGING MARKETS AND AXP PARTNERS INTERNATIONAL
SMALL CAP ONLY:

Funds that INVEST IN SECURITIES WHICH trade on overseas securities markets may
be vulnerable to market timers who seek to take advantage of changes in the
values of securities between the close of overseas markets and the close of U.S.
markets, which is generally the time at which a fund's NAV is calculated. TO THE
EXTENT THAT THE FUND HAS SIGNIFICANT HOLDINGS OF FOREIGN SECURITIES OR
SECURITIES THAT TRADE INFREQUENTLY, OR BOTH the risks of market timing may be
greater THAN FOR FUNDS THAT DO NOT HAVE SUCH HOLDINGS. See "Principal Investment
Strategies" for a discussion of the investment strategies that may result in the
Fund's investing in one or more of these asset classes. See also "Valuing Fund
Shares" for a discussion of the Fund's policy on fair value pricing, which is
intended, in part, to reduce the frequency and effect of market timing.

COMMENT 2: Under the "Valuing Fund Shares" section, your fund valuation
disclosure has no distinction in terms of holdings of the fund. Specifically, it
does not address "small-cap", "thinly-traded" or "illiquid" securities, please
include language that discloses information about these types of securities. In
addition, based on the level of holdings in a certain type of security, please
add a statement to address the fact that the risk would be greater.

RESPONSE: For each of the funds listed below, we have amended the "Valuing Fund
Shares" section to read as follows (changes are underlined): [Please see
attachment B for the full disclosure, including language that was removed].
<PAGE>

APPLICABLE TO AXP GLOBAL BOND, AXP GLOBAL TECHNOLOGY, AXP THREADNEEDLE GLOBAL
BALANCED, AXP THREADNEEDLE GLOBAL EQUITY, AXP THREADNEEDLE EUROPEAN EQUITY, AXP
THREADNEEDLE INTERNATIONAL, AXP PARTNERS INTERNATIONAL AGGRESSIVE GROWTH, AXP
PARTNERS INTERNATIONAL CORE, AND AXP PARTNERS INTERNATIONAL SELECT VALUE ONLY:

VALUING FUND SHARES

The NAV is the value of a single share of the Fund. The NAV is determined by
dividing the value of the Fund's assets, minus any liabilities, by the number of
shares outstanding. AEFC calculates the NAV as of the close of business on the
New York Stock Exchange (NYSE), normally 4:00 p.m. Eastern time, on each day
that the NYSE is open. THE FUND'S SECURITIES ARE VALUED PRIMARILY ON THE BASIS
OF MARKET QUOTATIONS OBTAINED FROM OUTSIDE PRICING SERVICES APPROVED BY THE
BOARD.

WHEN reliable MARKET quotations are not readily available, SECURITIES ARE PRICED
AT FAIR VALUE BASED ON PROCEDURES ADOPTED BY THE BOARD. These procedures are
ALSO used when THE VALUE OF A SECURITY HELD BY THE FUND IS MATERIALLY AFFECTED
BY EVENTS THAT OCCUR AFTER THE CLOSE OF THE PRIMARY MARKET ON WHICH THE SECURITY
IS TRADED BUT PRIOR TO THE TIME AS OF WHICH THE FUND'S NAV IS DETERMINED.
VALUING SECURITIES AT FAIR VALUE INVOLVES RELIANCE ON JUDGMENT. The fair value
of a security is likely to differ from ANY AVAILABLE quoted or published price.
TO THE EXTENT THAT THE FUND HAS SIGNIFICANT HOLDINGS OF FOREIGN SECURITIES, FAIR
VALUATION MAY BE USED MORE FREQUENTLY THAN FOR OTHER FUNDS. THE FUND USES AN
UNAFFILIATED SERVICE PROVIDER TO ASSIST IN DETERMINING FAIR VALUES FOR FOREIGN
SECURITIES.

Foreign investments are valued in U.S. dollars. Some of the Fund's securities
may be listed on foreign exchanges that trade on weekends or other days when the
Fund does not price its shares. In that event, the net asset value of the Fund's
shares may change on days when shareholders will not be able to purchase or
redeem the Fund's shares.
<PAGE>

APPLICABLE TO AXP THREADNEEDLE  EMERGING MARKETS AND AXP PARTNERS  INTERNATIONAL
SMALL CAP ONLY:

VALUING FUND SHARES

The NAV is the value of a single share of the Fund. The NAV is determined by
dividing the value of the Fund's assets, minus any liabilities, by the number of
shares outstanding. AEFC calculates the NAV as of the close of business on the
New York Stock Exchange (NYSE), normally 4:00 p.m. Eastern time, on each day
that the NYSE is open. THE FUND'S SECURITIES ARE VALUED PRIMARILY ON THE BASIS
OF MARKET QUOTATIONS OBTAINED FROM OUTSIDE PRICING SERVICES APPROVED BY THE
BOARD.

WHEN reliable MARKET quotations are not readily available, SECURITIES ARE PRICED
AT FAIR VALUE BASED ON PROCEDURES ADOPTED BY THE BOARD. These procedures are
ALSO used when THE VALUE OF A SECURITY HELD BY THE FUND IS MATERIALLY AFFECTED
BY EVENTS THAT OCCUR AFTER THE CLOSE OF THE PRIMARY MARKET ON WHICH THE SECURITY
IS TRADED BUT PRIOR TO THE TIME AS OF WHICH THE FUND'S NAV IS DETERMINED.
VALUING SECURITIES AT FAIR VALUE INVOLVES RELIANCE ON JUDGMENT. The fair value
of a security is likely to differ from ANY AVAILABLE quoted or published price.
TO THE EXTENT THAT THE FUND HAS SIGNIFICANT HOLDINGS OF FOREIGN SECURITIES OR
SECURITIES THAT TRADE INFREQUENTLY, OR BOTH, FAIR VALUATION MAY BE USED MORE
FREQUENTLY THAN FOR OTHER FUNDS. THE FUND USES A THIRD-PARTY SERVICE PROVIDER TO
ASSIST IN DETERMINING FAIR VALUES FOR FOREIGN SECURITIES.

Foreign investments are valued in U.S. dollars. Some of the Fund's securities
may be listed on foreign exchanges that trade on weekends or other days when the
Fund does not price its shares. In that event, the net asset value of the Fund's
shares may change on days when shareholders will not be able to purchase or
redeem the Fund's shares.

                      STATEMENT OF ADDITIONAL INFORMATION

APPLICABLE TO ALL FUNDS

COMMENT 3: Under the "Portfolio Holdings Disclosure" section, please disclose
"to whom, how frequently, and what information" you provide when disclosing the
Fund's selective disclosure of holdings information for ratings and rankings
agencies and for other third parties.

RESPONSE: We have amended the fifth paragraph under "Portfolio Holdings
Disclosure" to read as follows (changes are underlined): [Please see attachment
C for the full policy disclosure, including language that was removed].
<PAGE>

FROM TIME TO TIME, AEFC may make PARTIAL OR COMPLETE Fund holdings information
that is not publicly available on the website or otherwise available IN ADVANCE
OF THE TIME RESTRICTIONS NOTED ABOVE (1) to its directors, officers, and
employees, and those of its affiliated and unaffiliated service providers that
require the information IN THE NORMAL COURSE OF BUSINESS IN order to provide
services to the Fund (including, without limitation, custodians, auditors,
subadvisers, financial printers, pricing services, proxy voting services, AND
PARTIES THAT DELIVER ANALYTICAL, STATISTICAL, TRADING OR OTHER INVESTMENT
RELATED SERVICES), AND (2) TO FACILITATE THE REVIEW AND/OR RATING OF THE FUND BY
RATINGS AND RANKINGS AGENCIES (INCLUDING, FOR EXAMPLE, MORNINGSTAR, INC.,
THOMSON FINANCIAL AND LIPPER INC.). IN SUCH SITUATIONS, THE INFORMATION IS
RELEASED SUBJECT TO CONFIDENTIALITY AGREEMENTS, DUTIES IMPOSED UNDER APPLICABLE
POLICIES AND PROCEDURES (E.G., APPLICABLE CODES OF ETHICS) DESIGNED TO PREVENT
THE MISUSE OF CONFIDENTIAL INFORMATION, GENERAL DUTIES UNDER APPLICABLE LAWS AND
REGULATIONS, OR OTHER SUCH DUTIES OF CONFIDENTIALITY. In addition, the Fund
discloses holdings information as required by federal or state securities laws,
and may disclose holdings information in response to requests by governmental
authorities.

Staff had no additional comments except the requirement to make the following
representation on behalf of the Registrants:

In connection with the Amendments listed above, the Registrants, hereby
acknowledge the following:

     The  disclosures in the filings are the  responsibility  of the Registrants
     and the Registrants  are fully  responsible for the adequacy or accuracy of
     the  disclosures  in  these  filings.  The  Registrants  represent  to  the
     Commission  that  comments  made by the  Commission,  or the  staff  acting
     pursuant to delegated  authority,  or changes to  disclosure in response to
     staff  comments in the filing  reviewed by the staff,  do not foreclose the
     Commission  from  taking any action  with  respect to the  filing,  and the
     Registrants represent that they will 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.

If you have any questions,  please contact Christopher O. Petersen at (612) 671-
4321 or Simone Pepper at (612) 671-2847.

Sincerely,

/s/ Leslie L. Ogg
----------------
    Leslie L. Ogg
    Vice President, General Counsel and Secretary
<PAGE>

ATTACHMENT A - MARKET TIMING DISCLOSURE

REVISED MARKET TIMING DISCLOSURE

AXP GLOBAL BOND, AXP GLOBAL TECHNOLOGY, AXP THREADNEEDLE GLOBAL BALANCED, AXP
THREADNEEDLE GLOBAL EQUITY, AXP THREADNEEDLE EUROPEAN EQUITY, AXP THREADNEEDLE
INTERNATIONAL, AXP PARTNERS INTERNATIONAL AGGRESSIVE GROWTH, AXP PARTNERS
INTERNATIONAL CORE, AXP PARTNERS INTERNATIONAL SELECT VALUE

Market timing is frequent or short-term trading by certain shareholders intended
to profit at the expense of other shareholders by selling shares of a fund
shortly after purchase. Market timing may adversely impact a fund's performance
by preventing the portfolio manager from fully investing the assets of the fund,
diluting the value of shares held by long-term shareholders, or increasing the
fund's transaction costs.

Funds INVEST IN SECURITIES WHICH that trade on overseas securities markets may
be vulnerable to market timers who seek to take advantage of changes in the
values of securities between the close of overseas markets and the close of U.S.
markets, which is generally the time at which a fund's NAV is calculated.
[Further] TO THE EXTENT THAT THE FUND HAS SIGNIFICANT HOLDINGS OF FOREIGN
SECURITIES, the risks of market timing may be greater [for the funds] THAN FOR
[other] funds THAT DO NOT HAVE SIGNIFICANT FOREIGN HOLDINGS. See "Principal
Investment Strategies" for a discussion of the KINDS OF SECURITIES IN WHICH THE
FUND INVESTS. [investment strategies that may result in the Fund's investing in
one or more of these asset classes.] See also "Valuing Fund Shares" for a
discussion of the Fund's policy on fair value pricing, which is intended, in
part, to reduce the frequency and effect of market timing.

The Fund's Board of Directors has adopted a policy that is designed to detect
and deter market timing. The Fund seeks to enforce this policy through the
Distributor and its transfer agent as follows:

o    The Fund tries to  distinguish  market timing from trading that it believes
     is not  harmful,  such  as  periodic  rebalancing  for  purposes  of  asset
     allocation or dollar cost averaging. Under the Fund's procedures,  there is
     no set number of transactions in the Fund that  constitutes  market timing.
     Even one purchase  and  subsequent  sale by related  accounts may be market
     timing.  Generally, the Fund seeks to restrict the exchange privilege of an
     investor who makes more than three exchanges into or out of the Fund in any
     90-day period. Accounts held by a retirement plan or financial intermediary
     for the benefit of its  participants or clients,  which typically engage in
     daily  transactions,  are not subject to this limit.  The Distributor  does
     seek the  assistance of retirement  plans and financial  intermediaries  in
     applying similar  restrictions on the sub-accounts of their participants or
     clients.

o    If an  investor's  trading  activity is  determined  to be market timing or
     otherwise harmful to existing shareholders,  the Fund reserves the right to
     modify or  discontinue  the  investor's  exchange  privilege  or reject the
     investor's  purchases  or  exchanges,   including  purchases  or  exchanges
     accepted by a retirement plan or other financial intermediary. The Fund may
     treat  accounts it believes to be under common  control as a single account
     for  these  purposes,  although  it may not be able to  identify  all  such
     accounts.
<PAGE>

o    Although  the Fund  does not  knowingly  permit  market  timing,  it cannot
     guarantee  that it will be able to identify  and  restrict  all  short-term
     trading  activity.  The Fund  receives  purchase  and sale  orders  through
     retirement plans and financial  intermediaries where market-timing activity
     may not always be successfully detected.

AXP THREADNEEDLE EMERGING MARKETS; AXP PARTNERS INTERNATIONAL SMALL CAP

The language above is the same for these funds except for the second sentence in
the second paragraph, which should read as follows:

[Further] TO THE EXTENT THAT THE FUND HAS SIGNIFICANT HOLDINGS OF FOREIGN
SECURITIES OR SECURITIES THAT TRADE INFREQUENTLY, OR BOTH, the risks of market
timing may be greater [for the funds]TH