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Correspondence 0001193125-25-062665 from Invesco Ltd. (IVZ)

Invesco Ltd.
Date: March 25, 2025 · CIK: 0000914208 · Accession: 0001193125-25-062665

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File numbers found in text: 333-285194

Date
March 25, 2025
Author
Jeffrey H. Kupor
Form
CORRESP
Company
Invesco Ltd.

Letter

Re: Invesco Ltd. Registration Statement on Form S-3 File No. 333-285194 Ladies and Gentlemen: Invesco Ltd. (the “Company”) hereby requests, pursuant to Rule 461 of the General Rules and Regulations under the Securities Act of 1933, as amended, that the effective date of the above-referenced Registration Statement be accelerated so as to permit it to become effective at 5:00 p.m. EST on March 27, 2025, or as soon thereafter as practicable. Please contact Mark Kanaly or Rebecca Valentino of Alston & Bird LLP, the Company’s counsel, at (214) 922-3404 or (650) 838-2025, as soon as the Registration Statement has been declared effective, or if you have any other questions or concerns regarding this matter.

INVESCO LTD. March 25, 2025 VIA EDGAR Securities and Exchange Commission Division of Corporation Finance 100 F Street, N.E. Washington, D.C.

Invesco Ltd.

By:

/s/ Jeffrey H. Kupor

Name: Jeffrey H. Kupor

Title: Senior Managing Director and General Counsel

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CORRESP
 1
 filename1.htm

 CORRESP

 INVESCO LTD.
 March 25, 2025 VIA EDGAR
 Securities and Exchange Commission Division of
Corporation Finance 100 F Street, N.E. Washington, D.C.
20549

 Re:
 Invesco Ltd.
 Registration Statement on Form S-3
 File No. 333-285194
 Ladies and Gentlemen: Invesco
Ltd. (the “Company”) hereby requests, pursuant to Rule 461 of the General Rules and Regulations under the Securities Act of 1933, as amended, that the effective date of the above-referenced Registration Statement be accelerated so as to
permit it to become effective at 5:00 p.m. EST on March 27, 2025, or as soon thereafter as practicable. Please contact Mark Kanaly
or Rebecca Valentino of Alston & Bird LLP, the Company’s counsel, at (214) 922-3404 or (650) 838-2025, as soon as the Registration Statement has been
declared effective, or if you have any other questions or concerns regarding this matter.

 Invesco Ltd.

 By:

 /s/ Jeffrey H. Kupor

 Name: Jeffrey H. Kupor

 Title: Senior Managing Director and General Counsel