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CORRESP
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CORRESP

 February 25, 2020

VIA EDGAR

 U.S. Securities and Exchange
Commission

 Division of Investment Management

 100 F Street,
N.E.

 Washington, D.C. 20549-9303

Attention:           Ms. Jaea Hahn

Re:                     AIM Counselor Series Trust
(Invesco Counselor Series Trust)

                    File
No. 333-236069

          AIM Investment Funds (Invesco Investment Funds)

                    File
No. 333-236077

          AIM International Mutual Funds (Invesco
International Mutual Funds)

                    File
No. 333-236073

          AIM Investment Securities Funds (Invesco
Investment Securities Funds)

                    File
No. 333-236078

          AIM
Tax-Exempt Funds (Invesco Tax Exempt Funds)

                    File
No. 333-236076

          AIM Growth Series (Invesco Growth Series)

                    File
No. 333-236075

          Invesco Management Trust

                    File
No. 333-236081

          AIM Sector Funds (Invesco Sector Funds)

                    File
No. 333-236070

          AIM Sector Funds (Invesco Sector Funds)

                    File No. 333-236074

          AIM Variable
Insurance Funds (Invesco Variable Insurance Funds)

                    File No. 333-236071

          (each a
“Registrant” and collectively, the “Registrants”)

 Dear Ms. Hahn:

As requested, on behalf of the Registrants, I have attached the changed pages from the below-listed documents that reflect revisions made in
response to disclosure and accounting comments from the staff of the Securities and Exchange Commission:

(1)
 the Proxy Statement/Prospectus and related Pro Forma Narratives from the Statement of Additional Information
that relate to the reorganization of the Invesco Gold & Precious Metals Fund into Invesco Oppenheimer Gold & Special Minerals Fund which were included in the Registration Statement on Form
N-14 filed by AIM Sector Funds (Invesco Sector Funds) File No. 333-236074;

(2)
 the Proxy Statement/Prospectus and related Pro Forma Narratives from the Statement of Additional Information
that relate to the reorganization Invesco V.I. Mid Cap Growth Fund into Invesco Oppenheimer V.I. Discovery Mid Cap Growth Fund which were included in the Registration Statement on Form N-14 filed by AIM
Variable Insurance Funds (Invesco Variable Insurance Funds) File No. 333-236071; and

(3)
 the Joint Information Statement/Prospectus and related Pro Forma Narratives from the Statement of Additional
Information that relate to the reorganizations of 24 separate Invesco Funds and Invesco Oppenheimer Funds which were included in the Registration Statements on Form N-14 filed by AIM Counselor Series Trust
(Invesco Counselor Series Trust), File No. 333-236069, AIM Investment Funds (Invesco Investment Funds) File No. 333-236077, AIM International Mutual Funds (Invesco International Mutual Funds) File No. 333-236073, AIM Investment
Securities Funds (Invesco Investment Securities Funds) File No. 333-236078, AIM Tax-Exempt Funds (Invesco Tax Exempt Funds) File No. 333-236076, AIM Growth Series (Invesco Growth Series) File
No. 333-236075, Invesco Management Trust File No. 333-236081 and AIM Sector Funds (Invesco Sector Funds) File No. 333-236070).

The Registrant represents that (a) there are no other pages that contain material revisions and (b) that no additional material
revisions will be made to the following documents: (1) the Proxy Statement/Prospectus and Statement of Additional Information (including the Pro Forma Narratives) that relate to the reorganization of the Invesco Gold & Precious Metals
Fund into Invesco Oppenheimer Gold & Special Minerals Fund; (2) the Proxy Statement/Prospectus and Statement of Additional Information (including the Pro Forma Narratives) that relate to the reorganization Invesco V.I. Mid Cap Growth
Fund into Invesco Oppenheimer V.I. Discovery Mid Cap Growth Fund and (3) the Joint Information Statement/Prospectus and Statement of Additional Information (including the Pro Forma Narratives) that relate to the reorganization of 24 separate
Invesco Funds and Invesco Oppenheimer Funds.

 2

 If, however, you have any further questions, please contact me at (215) 564-8149 or in my absence, Taylor Edwards, Esq. at (212) 652-4208.

Sincerely,

 /s/ Kenneth. L.
Greenberg

 Kenneth L. Greenberg, Esq

 3

 PROPOSAL: TO APPROVE AN AGREEMENT AND PLAN OF REORGANIZATION

Shareholders of the Target Fund are being asked to consider and approve an Agreement and Plan of Reorganization (the
“Agreement”) that will have the effect of reorganizing the Target Fund with and into the Acquiring Fund, as summarized below. The Agreement provides for (a) the transfer of all or substantially all of the assets (as defined in the
Agreement) and assumption of the liabilities (as defined in the Agreement) of the Target Fund by the Acquiring Fund in exchange for shares of a corresponding class of the Acquiring Fund; (b) the distribution of such shares of the corresponding
class to the shareholders of the Target Fund; and (c) the distribution of shares in complete liquidation of the Target Fund and the cancellation of the outstanding shares of the Target Fund (the “Reorganization”).

SUMMARY OF KEY INFORMATION

The following is a summary of certain information contained elsewhere in this Proxy Statement/Prospectus, in the Agreement,
and/or in the prospectuses and SAIs of the Funds. Shareholders should read the entire Proxy Statement/Prospectus and the prospectus of the Acquiring Fund carefully for more complete information.

On what am I being asked to vote?

As a shareholder of the Target Fund, you are being asked to consider and vote to approve the Agreement under which the assets
and liabilities of the Target Fund will be transferred to the Acquiring Fund.

 If the shareholders of the Target Fund vote
to approve the Agreement, then shareholders of the Target Fund will become shareholders of the Acquiring Fund on or about May 15, 2020 and will no longer be shareholders of the Target Fund. Shareholders of the Target Fund will receive shares of
the Acquiring Fund (“Acquiring Fund Shares”) with an aggregate net asset value (“NAV”) equivalent to their investment in the corresponding class of shares of the Target Fund as noted in the chart below.

Target Fund

Acquiring Fund

 Class A

Class A

 Class C

Class C

 Investor

Class A

 Class Y

Class Y

Class R6

Class R6

 Because the Funds have different NAVs per share, the number of Acquiring Fund Shares that you
receive will likely be different than the number of shares of the Target Fund that you own, but the total value of your investment will be the same immediately before and after the exchange. After the Acquiring Fund Shares are distributed to the
Target Fund’s shareholders, the Target Fund will be completely liquidated and dissolved.

 Has my Fund’s Board of
Trustees approved the Reorganization?

 Yes. The Board has carefully reviewed the proposal and unanimously approved the
Agreement and the Reorganization. The Board recommends that shareholders of the Target Fund vote in favor of the Agreement.

What are the reasons for the proposed Reorganization?

  On May 24, 2019, Invesco Ltd.
(“Invesco”), the indirect parent company of Invesco Advisers, Inc., the Funds’ investment adviser (“Invesco Advisers” or “Adviser”), acquired OppenheimerFunds, Inc. and its subsidiaries (collectively,
“OFI”), which included OFI’s mutual fund business comprised of 83 Oppenheimer branded funds. This transaction created a larger family of funds that offers a broader range of equity, fixed income, alternative and other investment
options. The transaction also resulted in product overlap within Invesco’s mutual fund platform. The Reorganization proposed in this Proxy Statement/Prospectus is part of a larger group of reorganizations occurring across Invesco’s mutual
fund platform. The reorganizations are designed to allow Invesco to put forth its most compelling investment processes and strategies, reduce product overlap, ensure the resulting funds can be clearly distinguished in the marketplace, and build a
solid foundation for further growth of a mutual fund platform that is economically viable and sustainable.

   The
Reorganization is also intended to create a larger combined Fund with a more diversified shareholder base and a larger asset base against which fixed dollar costs may be allocated and potentially create economies of scale to benefit shareholders.

  In considering the Reorganization and the Agreement, the Board considered these and other factors in concluding that
the Reorganization would be in the best interest of the Funds. The Board’s considerations are described in more detail in the “THE PROPOSED REORGANIZATION — Board Considerations in Approving the Reorganization” section below.

 1

 What effect will the Reorganization have on me as a shareholder?

Immediately after the Reorganization, you will hold shares of a class of the Acquiring Fund that are equal in value to the
shares of the corresponding class of the Target Fund that you held immediately prior to the closing of the Reorganization. The principal differences between the Target Fund and the Acquiring Fund are described in this Proxy
Statement/Prospectus. The prospectus of the Acquiring Fund that accompanies this Proxy Statement/Prospectus contains additional information about the Acquiring Fund that you will hold shares of following the Reorganization, if approved by
shareholders.

  As described in more detail in “FEDERAL INCOME TAX CONSIDERATIONS — Repositioning of the
Target Fund’s Portfolio Assets” below, a portion of the Target Fund’s portfolio assets may be sold in connection with the Reorganization (as distinct from normal portfolio turnover). The Adviser anticipates selling a
significant portion of the Target Fund’s portfolio assets; however, shareholders, depending on the position of the Fund at the time of the repositioning, as described further below, are not likely to realize capital gains. The Target Fund will
also bear the associated brokerage costs of repositioning of the Fund’s portfolio.

   Combining the assets of
the Target Fund ($223.9 million as of October 31, 2019) and the Acquiring Fund ($1,276.2 million as of October 31, 2019) will allow the fixed costs of the Funds to be spread over a larger asset base.

What are the costs of the Reorganization and who is responsible for paying the costs?

The total cost of the Reorganization to be paid by the Target Fund is estimated to be $290,000. The costs of the Reorganization
include legal counsel fees, independent accountant fees, expenses related to the printing and mailing of this Proxy Statement/Prospectus and fees associated with the proxy solicitation but do not include any portfolio transaction costs arising from
the Reorganization.

  How do the Funds’ investment objectives, principal investment strategies and risks compare?

 Investment Objectives. The Funds’ investment objectives are substantially the same. The Acquiring Fund
seeks long-term growth of capital and the Target Fund seeks capital appreciation. Whereas the Target Fund’s investment objective is classified as non-fundamental, which means that it can be changed by the
Board without shareholder approval, the Acquiring Fund’s investment objective is classified as fundamental and cannot be changed without shareholder approval.

Investment Strategy and Risks. The principal investment strategies of the Acquiring Fund are similar to the principal
investment strategies of the Target Fund. Both the Target Fund and Acquiring Fund invest primarily in equity securities of U.S. and foreign issuers that focus on doing business in the gold and special minerals sector. The Target Fund and Acquiring
Fund have different policies with respect to the ability to invest directly or indirectly in actual precious metals. The Target Fund may invest directly or indirectly up to 10% of its net assets in gold bullion. The Acquiring Fund has a more
expansive policy in that it may invest up to 20% of its total assets in gold or silver bullion, in other precious metals, in metals naturally occurring with precious metals, in certificates representing an ownership interest in those metals, and in
gold or silver coins. The Target Fund and Acquiring Fund also may both invest in derivatives, but the Acquiring Fund may be exposed to a broader array of derivatives, such as commodity futures, financial futures, options and swap contracts, and
other commodity-linked investments through its ability to invest in a wholly-owned subsidiary (the “Subsidiary”). The Acquiring Fund also has different investment policies and limitations than the Target Fund. As a result, the risks of
owning shares of the Acquiring Fund are similar to the risks of owning shares of the Target Fund, although the risks of the Funds may not be exactly the same.

In addition, the Acquiring Fund, but not the Target Fund, is non-diversified under the Investment Company Act of 1940, as
amended (the “1940 Act”), which means that the Acquiring Fund may invest a greater portion of its assets in the securities of a single issuer than if it were a diversified fund. The sections below entitled “ADDITIONAL INFORMATION
ABOUT THE FUNDS — Comparison of Principal Investment Strategies” and “Comparison of the Principal Risks of Investing in the Funds” compare the principal investment strategies and risks of the Target Fund and the Acquiring Fund,
including the risks associated with the Acquiring Fund’s investments in the Subsidiary and its classification as a non-diversified fund, and highlight certain key differences.

How do the Funds’ expenses compare?

The tables below provide a summary comparison of the expenses of the Target Fund and the Acquiring Fund, as well as estimated
expenses on a pro forma basis giving effect to the proposed Reorganization. The pro forma expense ratios show projected estimated expenses, but actual expenses may be greater or less than those shown.

 2

 Expense Tables and Expense Examples*

Current

Pro Forma

Target Fund

Acquiring
Fund

 Target Fund

+

Acquiring Fund

(assumes

Reorganization is

completed)

Class A

Class A

Class A

 Shareholder Fees
(Fees paid directly from your investment)

Maximum Sales Charge (Load) Imposed on Purchases (as a percentage of offering price)

5.50
%

5.50
%

5.50
%

 Maximum Deferred Sales Charge (Load) (as a
percentage of original purchase price or redemption proceeds, whichever is less)

None
1

None
1

None
1

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

 Management Fees

0.75
%

0.65
%

0.62
%

Distribution and Service (12b-1) Fees

0.25
%

0.24
%

0.23
%

 Other Expenses

0.52
%

0.33
%2

0.33
%

Total Annual Fund Operating Expenses

1.52
%

1.22
%

1.18
%

 Fee Waiver
and/or Expense Reimbursement

0.00
%

0.05
%3

0.01
%3

 Total
Annual Fund Operating Expenses after Fee Waiver and/or Expense Reimbursement

1.52
%

1.17
%

1.17
%

Current

Pro Forma

Target Fund

 Acquiring

Fund

 Target Fund

+

Acquiring Fund

(assumes
Reorganization is

completed)

Class C

Class C

Class C

 Shareholder Fees
(Fees paid directly from your investment)

Maximum Sales Charge (Load) Imposed on Purchases (as a percentage of offering price)

None

None

None

 Maximum Deferred Sales Charge (Load) (as a
percentage of original purchase price or redemption proceeds, whichever is less)

1.00
%

1.00
%4

1.00
%

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

 Management Fees

0.75
%

0.65
%

0.62
%

Distribution and Service (12b-1) Fees

1.00
%

1.00
%

1.00
%

 Other Expenses

0.52
%

0.33
%2

0.33
%

Total Annual Fund Operating Expenses

2.27
%

1.98
%

1.95
%

 Fee Waiver
and/or Expense Reimbursement

0.00
%

0.06
%3

0.03
%3

 Total
Annual Fund Operating Expenses after Fee Waiver and/or Expense Reimburse