[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
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James F. Lummanick
Vice President and
Assistant General Counsel
JFL/slj