IDS LIFE INVESTMENT SERIES INC, 497J, 1999-08-16

IDS LIFE INVESTMENT SERIES INC
497J, 1999-08-16

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August 13, 1999



Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C. 20549-1004

ATTN:  Ms. Zandra Y. Bailes, Document Control - EDGAR

Re:    AXP Variable Portfolio - Investment Series, Inc. formerly known as
       IDS Life Investment Series, Inc.
          AXP Variable Portfolio - Blue Chip Advantage Fund
          AXP Variable Portfolio - Growth Fund
          AXP Variable Portfolio - Small Cap Advantage Fund
       Post-Effective Amendment No. 38
       File No. 2-73115/811-3218

Dear Ms. Bailes:

Registrant  certifies  that the form of  prospectus  and Statement of Additional
Information that would have been filed under paragraph (c) of Rule 497 would not
have differed from that contained in the most recent  Registration  Statement or
Amendment,  and the text of the most recent Registration  Statement or Amendment
has been filed electronically.

Sincerely,

AXP VARIABLE PORTFOLIO - INVESTMENT SERIES, INC.
    AXP Variable Portfolio - Blue Chip Advantage Fund
    AXP Variable Portfolio - Growth Fund
    AXP Variable Portfolio - Small Cap Advantage Fund






/s/ Leslie L. Ogg
Leslie L. Ogg
Vice President

LLO/BS/dm