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ALTERNATIVE
INVESTMENT PARTNERS ABSOLUTE RETURN FUND STS

100 Front Street, Suite 400

West Conshohocken, Pennsylvania 19428

VIA EDGAR

November 4, 2021

Securities and Exchange Commission

Division of Investment Management

100 F Street, NE

Washington, D.C. 20549

    Attn:
    Valerie J. Lithotomos

    Re:
    Alternative Investment Partners Absolute Return Fund
    STS

    Pre-Effective Amendment No. 1 to the Registration
    Statement on Form N-2

    SEC File Nos. 333-259623; 811-21831

Dear Ms. Lithotomos:

Pursuant to Rule 461 under the Securities Act of 1933,
as amended, Alternative Investment Partners Absolute Return Fund STS (the “Registrant”) hereby requests that the effective
date of Pre-Effective Amendment No. 2 to the Registration Statement on Form N-2 (the “Registration Statement”) be accelerated
so that the Registration Statement may become effective at 5:00 p.m., Eastern Time, on November 5, 2021, or as soon as practicable thereafter.

In connection with this request, the Registrant hereby
acknowledges that (i) should the U.S. Securities and Exchange Commission (“Commission”) or its staff, acting pursuant to delegated
authority, declare the Registration Statement effective, such action will not foreclose the Commission from taking any action with respect
to the Registration Statement; (ii) the action of the Commission or its staff, acting pursuant to delegated authority, in declaring the
Registration Statement effective, will not relieve the Registrant from its full responsibility for the adequacy and accuracy of the disclosure
in the Registration Statement; and (iii) the Registrant may not assert such action as a defense in any proceeding initiated by the Commission
under the federal securities laws of the United States.

The Registrant requests that notification of such effectiveness
be made by telephone call to Jonathan Gaines of Dechert LLP, legal counsel to the Registrant, at 212-641-5600.

Very truly yours,

Alternative investment partners
Absolute return fund STS

    By:
    /s/ Allan
    Fajardo

    Name:
    Allan Fajardo

    Title:
    Assistant Secretary

Morgan Stanley
Distribution, Inc.

522 Fifth Avenue

New York, New York 10036

VIA EDGAR

November 4, 2021

Securities and Exchange Commission

Division of Investment Management

100 F Street, NE

Washington, D.C. 20549

    Attn:
    Valerie J. Lithotomos

    Re:
    Alternative Investment Partners Absolute Return Fund
    STS

    Pre-Effective Amendment No. 1 to the Registration
    Statement on Form N-2

    SEC File Nos. 333-259623; 811-21831

Dear Ms. Lithotomos:

Pursuant to Rule 461 under the Securities Act of 1933,
as amended (the “1933 Act”), Morgan Stanley Distribution, Inc., in its capacity as distributor of Alternative Investment Partners
Absolute Return Fund STS (the “Fund”), hereby joins in the request of the Fund for acceleration of the effective date of Pre-Effective
Amendment No. 2 to the Registration Statement on Form N-2 (the “Registration Statement”) so that such Registration Statement
may be declared effective at 5:00 p.m., Eastern Time, on November 5, 2021, or as soon as practicable thereafter.

The undersigned, in making this request for acceleration, hereby states
that it is aware of its obligations under Rule 461 and the other applicable provisions of the 1933 Act.

Very truly yours,

Morgan Stanley Distribution,
Inc.

    By:
    /s/ Matthew
    Graver

    Name:
    Matthew Graver

    Title:
    Managing Director