INVESCO SPECIALTY FUNDS INC
497J, 1997-10-03
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INVESCO FUNDS GROUP, INC.
7800 East Union Avenue
Denver, Colorado 80217
Post Office Box 173706
Denver, Colorado 80217-3706
Telephone:  303-930-6300



October 3, 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  "Fund"),  hereby
submits for filing on EDGAR this  certification  that the definitive form of its
Statement of Additional Information dated October 1, 1997, for filing under Rule
497(j) does not differ from that contained in the  Post-Effective  Amendment No.
13 under the  Securities  Act of 1933 and Amendment No. 14 under the  Investment
Company   Act  of  1940  to  the  Fund's   Registration   Statement   which  was
electronically   filed  pursuant  to  Rule  485(b)  on  October  1,  1997.  This
Post-Effective Amendment became effective October 1, 1997.

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

Sincerely,

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


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