INVESCO SPECIALTY FUNDS INC
497J, 1999-11-15
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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




November 15, 1999



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 497j),  INVESCO  Specialty  Funds,  Inc. (the "Fund"),  hereby
submits for filing on EDGAR this  certification  that the definitive form of its
Prospectuses for INVESCO Realty Fund and INVESCO Telecommunications 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. 17 under the Securities
Act of 1933 and Amendment No. 18 under the Investment Company Act of 1940 to the
Fund's Registration  Statement,  which was electronically filed pursuant to Rule
485(b) on November 12, 1999.  This  Post-Effective  Amendment  became  effective
November 12, 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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