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Seward & Kissel LLP

901 K Street, NW

Suite 800

Washington, DC 20001

Telephone: (202) 737-8833

Facsimile: (202) 737-5184

www.sewkis.com

    December 30, 2021

Via EDGAR CORRESPONDENCE

Mr. Sonny Oh

Division of Investment Management

Securities and Exchange Commission

100 F Street, NE

Washington, DC 20549

    Re:

    AB Variable Products Series Fund, Inc

    - AB International Growth Portfolio

    Post-Effective Amendment No. 86

    File Nos. 033-18647 and 811-05398

Dear Mr. Oh:

This letter responds to comments
of the staff of the Securities and Exchange Commission (the "Staff") to the above-referenced post-effective amendment to the
registration statement filed on November 5, 2021 (the "Post-Effective Amendment"), on Form N-1A for AB International Growth
Portfolio (the "Portfolio"), a series of AB Variable Products Series Fund, Inc. (the "Registrant"). You provided the
Staff's comments to Lancelot A. King and me by telephone on December 21, 2021.

The Staff's comments and our responses
thereto on behalf of the Registrant and the Portfolio are set forth below. The changes referenced in the responses are indicated in the
attached and will also be reflected in a Rule 497 filing.

Please note that the Portfolio
has certain principal strategies that are similar to those of other AB Sustainable Funds with respect to (1) the incorporation of sustainable
investment themes that are aligned with the United Nations Sustainable Development Goals and (2) the evaluation of risks relating to ESG
factors, alongside more traditional financial metrics, for company portfolio holdings. In connection with its reviews of the Rule 485(a)
filings for the AB Sustainable Funds to-date, the Staff has issued comments on prospectus disclosures that are similar to a number of
the comments made herein (e.g., Comment 14 through Comment 18), and the funds have made disclosure changes in response to such
comments. Please see EDGAR Correspondence filed for (1) AB Sustainable Thematic Balanced Portfolio, a series of The AB Portfolios (File
Nos. 33-12988 and 811-05088) on November 24, 2021 (SEC Accession No. 0000919574-21-007245); (2)

AB Sustainable US Thematic Portfolio, a series of
AB Cap Fund, Inc. (File Nos. 2-9901 and 811-01716) on August 13, 2021 (Accession No. 0000919574-21-005143), August 19, 2021 (Accession
No. 0000919574-21-005489) and August 24, 2021 (SEC Accession No. 0000919574-21-005537); and (3) AB Sustainable Thematic Credit Portfolio,
a series of AB Bond Fund, Inc. (File Nos. 2-48227 and 811-02383) on April 16, 2021 (SEC Accession No. 0000919574-21-003014). The disclosure
changes previously reviewed by the Staff are reflected in the disclosure, as applicable, for the Portfolio.

Prospectus

Cover Page

    Comment 1:
    The Prospectus should be dated as of January 4, 2022 rather than "May 1, 2021, as revised January 4, 2022."

    Response:
    The Prospectus will be revised in response to this comment.

Summary Information

    Comment 2:
    The last sentence under "Fees and Expenses of the Portfolio" indicates that certain charges at the separate account level or contract level may apply to Contractholders and increase the fees and expenses provided in the tables.  Corresponding disclosure should be added under "Examples" to indicate such charges may also increase the amounts provided in the hypothetical expense example.

    Response:
    The Prospectus will be revised in response to this comment.

    Comment 3:
    Please revise the language in the first sentence under "Fees and Expenses of the Portfolio" to reflect that the table describes the fees that a Contractholder may pay if they buy, hold and sell shares of the Portfolio.

    Response:
    The Prospectus will be revised in response to this comment.

 General

    Comment 4:
    Please supplementally inform the Staff why the Board of Directors believes that these changes are consistent with its fiduciary duties and are in the best interest of the Contractholders who did not vote for these changes:

    (a) Explain what information the Board considered
    and how it weighed the information in arriving at its decision;

    (b) Explain why the Board concluded that this approach
    was better for Contractholders than any other alternatives, such as liquidating the Portfolio and starting a new portfolio; and

    (c) Support your explanation of the Board's deliberation
    with data. For example, if costs were a consideration, provide data supporting the expected cost savings of the proposed changes as compared
    with starting a new portfolio.

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    Response:
    The Portfolio's Board of Directors considered extensive amounts of information provided by the Adviser regarding the proposed changes during the course of its meetings on November 2-4, 2021, including, among other things, a memorandum from the Adviser, a written and oral presentation from the Adviser, a draft revised prospectus and a draft prospectus supplement. The Adviser's memorandum and other materials addressed, among other things, the Adviser's rationale for recommending the proposed changes and its assessment of the likely implications to the Portfolio of making the proposed changes. The Adviser informed the Board that the Portfolio's holdings would continue to consist primarily of non-U.S. securities with a growth orientation and that the Portfolio's holdings were not expected to change as a result of the proposed changes. The Adviser also informed the Board that it believed that the proposed changes will better reflect the investment approach of the Adviser with respect to the Portfolio and facilitate the marketing of the Portfolio.

    Given the nature of the proposed changes, including the fact that they were intended to better reflect the investment approach of the Adviser with respect to the Portfolio and were not expected to result in changes to the Portfolio's holdings, the Board was not presented with, and did not consider, alternatives to making the proposed changes (other than not approving them), including the alternative of liquidation of the Portfolio and the launch of a new portfolio. The Board considered that Contractholders would be provided with advance notice of the changes and would have the opportunity to redeem or sell their shares of the Portfolio if they did not wish to continue their investment in it, and that the Adviser planned to work with the Contractholders' insurance companies so that such insurance companies understand the changes and their rationales. The Board reviewed the Adviser's analysis of the anticipated cost implications of approving the changes, noting that such costs were modest and considered whether it was reasonable for such costs to be borne by the Portfolio. The Board also considered the distribution implications of the Adviser's proposal as noted above. During the presentation of the proposed changes at the Board meeting, the questions of the Directors were responded to by representatives of the Adviser to the satisfaction of the Directors.

    The Independent Directors met separately to discuss the proposed changes, and after evaluation of all of the information presented to them, and having had the chance to discuss the proposal with representatives of the Adviser and their independent counsel and applying their business judgment, agreed that the Adviser's proposal was in the best interests of the Portfolio, and  recommended the proposed changes to the full Board for its approval.

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    The Independent Directors did not identify any particular factor as controlling in reaching their determination, and individual Directors may have placed varying degrees of importance on different pieces of information. The Board subsequently acted upon the recommendation of the Independent Directors and approved the Adviser's proposal. The Board believes that it acted with due care in considering the Adviser's proposal and that the changes are in the best interests of the Portfolio and its Contractholders.

    The Portfolio's Prospectus was supplemented following approval of the changes by the Board.

    Disclosures in the Prospectus and statement of additional information of the Portfolio indicate that the Portfolio's investment strategies are not fundamental policies and may be changed by the Board of Directors without Contractholder approval. Furthermore, as noted below, Contractholders were provided advance notice of the changes. Registrant believes that a change of this nature is consistent with actions taken by fund boards in the ordinary course of business without Contractholder approval.

    Comment 5:
    Please also explain why the Adviser believes the changes are consistent with its fiduciary duty to the Portfolio.

    Response:
    The Adviser believes that the changes are consistent
    with its fiduciary duty to the Portfolio because the changes better reflect the investment approach of the Adviser with respect to
    the Portfolio and it believes that the changes are in the Contractholders' best interests. The changes are consistent with the
    Portfolio's objective to achieve long-term growth of capital and permit Contractholders to continue to be invested in a portfolio
    that consists primarily of non-U.S. securities with a growth orientation. The Registrant notes that Contractholders have been
    provided advance notice of the changes and have the opportunity to redeem or exchange their Portfolio shares prior to the effective
    date of the changes if they do not wish to continue their investment in the Portfolio.

    Comment 6:
    Please supplementally disclose whether the Portfolio has notified Contractholders of the planned changes. If so, please provide a copy of the notice and explain how it was sent to Contractholders.

    Response:
    The Registrant filed a prospectus supplement describing the planned changes for the Portfolio on November 5, 2021 (SEC Accession No. 0000919574-21-006636). A copy of the notice is attached to this response letter. The prospectus supplement was distributed to the life insurance companies ("Insurers") that offer shares of the Portfolio through their separate accounts.

    Comment 7:
    Please supplementally disclose the composition of the Contractholder base of the Portfolio (e.g., Contractholders vs. institutional).

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    Response:
    The Portfolio offers it shares through separate accounts of the Insurers. The Registrant does not have transparency into those accounts to determine the composition of the Portfolio's beneficial Contractholder base.

    Comment 8:
    Please explain supplementally why making the changes in a post-effective amendment to the registration statement of an existing Portfolio, as opposed to an amendment adding a new portfolio is consistent with the text and policy of Rule 485(a) under the Securities Act. Also explain why the Registrant believes this approach does not provide an unfair competitive advantage over other registrants who may have chosen to add a new series under a Rule 485(a) amendment that becomes effective within 75 days as opposed to 60 days.

    Response:
    The changes are reflected in a post-effective amendment to the registration statement of an existing Portfolio because the post-effective amendment was filed for the purpose of making material changes to an existing series in accordance with Rule 485(a)(1), rather than adding a new series, in accordance with Rule 485(a)(2) under the Securities Act.  It would be inappropriate for an existing series to file under Rule 485(b)(2).  A filing pursuant to Rule 485(a)(1) under these circumstances is appropriate and consistent with the text and policy of Rule 485 and industry practice.

    The Registrant does not believe that filing under Rule 485(a)(1) provides an unfair competitive advantage over other registrants because the Registrant is adhering to the rules promulgated under the Securities Act and the Staff's pronouncements thereon. Registrant notes that the changes to the registration statement are publicly available for 60 days prior to the effectiveness of the registration statement and that such changes are subject to review by the Staff.

    Comment 9:
    Please inform the Staff what percentage of the Portfolio's current portfolio will be repositioned as a result of the changes.

    Response:
    The Adviser does not expect any repositioning as a result of the changes.

    Comment 10:
    Please supplementally disclose whether any Contractholder has contacted the Registrant, Portfolio or an intermediary regarding the planned changes in investment strategy. If so, describe the nature of the communication and whether anyone has expressed dissatisfaction or threatened legal action with respect to such changes.

    Response:
    The Registrant confirms that no Contractholder or Insurer that offer shares of the Portfolio through its separate accounts has contacted the Portfolio objecting to, or threatening legal action regarding, the planned changes to the Portfolio's investment strategies.

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    Comment 11:
    With respect to the upcoming name change of the Portfolio, please supplementally explain if the Portfolio intends to file another Rule 485(a) filing to reflect the name change.

    Response:
    The Registrant intends to reflect the name change of the Portfolio in a Rule 485(b) filing at the time of its annual update filing. The prospectus supplement referred to above indicated that the Portfolio's name will be changed on or about May 1, 2022 (i.e., the expected date of such Rule 485(b) filing).

Summary Information

    Comment 12:
    Please expand on the meaning of the term "focused" as used in the first sentence under the "Principal Strategies" section.

    Response:
    Registrant notes that the term "focused" used in the phrase "focused international portfolio of equity securities of companies" is intended to indicate that the Portfolio invests in a limited number of companies. The disclosures under "Focused Portfolio Risk" in the "Principal Risks" section explain that the term "focused portfolio" means "investments in a limited number of companies" and describe the related risks of this strategy.

    Comment 13:
    The disclosure under "Principal Strategies" should reflect a growth strategy, as the Portfolio still has the term "growth" in its name.

    Response:
    The Prospectus will be revised in response to this comment.

    Comment 14:
    Under "Principal Strategies," please rephrase "believes position the company to benefit from certain sustainable investment themes" to better describe what exactly it means "to benefit from certain sustainable investment themes".

    Response:
    The Registrant has reviewed the referenced disclosure and believes it is sufficiently clear for investors. Registrant believes that the word "benefit" is not a technical term and is used in a clear, "plain English" manner to indicate that the business activities of the companies that the Adviser considers for investment permit such companies to be positively impacted by the advancement of health, climate and empowerment.

    Comment 15:
    Under "Principal Strategies," please disclose what underlying data will be reviewed by the Adviser and the sources of such data. For example, will the Adviser engage with portfolio companies to understand the companies' sustainability practices or will the Adviser use other types of information or outside sources?

    6

    Response:
    The Portfolio's disclosures explain that the Adviser relies on its own internal research and analysis (as opposed to, for example, third party ESG scoring systems) for its sustainability assessments (which is proprietary). Registrant does not believe that further detail is required or necessary.

    Comment 16:
    Under "Principal Strategies," please clarify what the Adviser is analyzing to determine companies which "fit into sust