SecProbe.io

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November 19, 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 Partners International Series, Inc.
                           AXP Partners International Core Fund
                           Post -Effective Amendment No. 8 ("Amendment No. 8")
                           File Nos. 333-64010 / 811-10427

Dear Ms. Mengiste:

This letter is in response to Staff's oral comments that you communicated to us
by telephone on or about November 10, 2004 for the fund referenced above.

                                   PROSPECTUS

Comment 1: Page 7p. Under footnote (c) in the Average Annual Total Return table
of the "Past Performance" section, state the timeframe for the fee waivers.

Response: The fee waivers will continue through the next fiscal year end for the
          fund. The footnote has been revised as follows:

     AEFC and its affiliates have contractually agreed to waive certain fees and
     to  absorb  certain  expenses  until  October  31,  2005,  and  will not be
     reimbursed by the Fund. Under this agreement,  net expenses will not exceed
     _____% for Class A;  _____% for Class B;  _____% for Class C and _____% for
     Class Y.

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

In connection with Amendment No. 8, the Registrant, hereby acknowledges the
following:

     The disclosures in the filing are the  responsibility of the Registrant and
     the  Registrant  is fully  responsible  for the adequacy or accuracy of the
     disclosures  in this filing.  The  Registrant  represents 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 Registrant represents
     that  it 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

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