INVESCO SPECIALTY FUNDS INC
497J, 1997-07-01
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INVESCO Funds Group, Inc.
7800 E. Union Avenue
Denver, Colorado  80237
(303) 930-6300


June 30, 1997



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

RE:   INVESCO Specialty Funds, Inc.
      1933 Act No. 033-79290
      1940 Act No. 811-8528
      CIK No. 0000923705

Ladies and Gentlemen:

Pursuant  to  Rule  497(j)  of the  Securities  Act of  1933  (the  "1933  Act")
(submission type 497),  INVESCO  Specialty Funds,  Inc. (the "Company"),  hereby
submits for filing on EDGAR this  certification  that the definitive form of its
Prospectus  for INVESCO  Realty Fund and the  Company's  Statement of Additional
Information  for filing under Rule 497(j) does not differ from that contained in
the  Post-Effective  Amendment  No.  11  under  the  Securities  Act of 1933 and
Amendment  No.  12 under the  Investment  Company  Act of 1940 to the  Company's
Registration Statement which was electronically filed pursuant to Rule 485(b) on
June 27, 1997. This Post-Effective Amendment is to become effective today.

If you have any  questions  or  comments,  please  contact  the  undersigned  at
303/930-6200.

Sincerely,

/s/ Glen A. Payne
- -----------------
Glen A. Payne
Senior Vice President,
  Secretary and General Counsel




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