INVESCO VARIABLE INVESTMENT FUNDS INC
497J, 1999-10-12
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[INVESCO ICON] INVESCO FUNDS                        INVESCO FUNDS GROUP, INC.
                                                    7800 East Union Avenue
                                                    Denver, Colorado 80237
                                                    Post Office Box 173706
                                                    Denver, Colorado 80217-3706
                                                    Telephone: 303-930-6300


October 11, 1999



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

RE:   INVESCO VARIABLE INVESTMENT FUNDS, INC.
      1933 ACT NO. 033-70154
      1940 ACT NO. 811-8038
      CIK NO. 0000912744

Ladies and Gentlemen:

Pursuant  to  Rule  497(j)  of the  Securities  Act of  1933  (the  "1933  Act")
(submission type 497j),  INVESCO Variable  Investment  Funds, Inc. (the "Fund"),
hereby submits for filing on EDGAR this  certification  that the definitive form
of its  Prospectus  for INVESCO VIF-Market  Neutral  Fund and the  Statement of
Additional  Information  for filing  under Rule 497(j) does not differ from that
contained in the  Post-Effective  Amendment No. 18 under the  Securities  Act of
1933 and Amendment No. 19 under the Investment Company Act of 1940 to the Fund's
Registration Statement which was electronically filed pursuant to Rule 485(b) on
October 8, 1999. This Post-Effective Amendment became effective October 8, 1999.

If you have any questions or comments,  please contact the  undersigned at (303)
930-6526.

Sincerely,


/s/ James F. Lummanick
- -------------------------
James F. Lummanick
Vice President and
Assistant General Counsel


JFL/slj





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