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11 Greenway Plaza, Suite 100
Houston, TX 77046-1173
713-626-1919

Invesco Aim Advisors, Inc.

April 22, 2009

VIA EDGAR

Mr. James O'Connor
Division of Investment Management
U.S. Securities and Exchange Commission
100 F St., NE
Washington, DC 20549

Re:  AIM Equity Funds (AEF)
     Post-Effective Amendment No. 92 to
     Form N-1A Registration Statement
     File No. 002-25469; CIK No. 0000105377

Dear Mr. O'Connor:

     This letter responds to the Staff's comments on the above-referenced
Registration Statement on Form N-1A filed by AIM Equity Funds (the "Registrant")
on February 20, 2009 which is scheduled to go effective May 13, 2009.

Staff's Comment:

1.   HYPOTHETICAL INVESTMENT AND EXPENSE INFORMATION

     Consider clarifying the lead-in language to section of the the registration
     statement entitled Hypothetical Investment and Expense Information
     regarding the settlement agreement between Invesco Aim Advisors, Inc. and
     certain of its affiliates and the New York Attorney General's office.

Response:

     The introductory language to the Hypothetical Investment and Expense
Information section of the registration statement was initially drafted together
with the New York Attorney General's Office and then collectively modified by
the Registrant's investment advisor and the Staff. We agree that we need to
define "the settlement" and therefore propose the following change to the
disclosure:

     In connection with the final settlement reached between Invesco Aim
     Advisors, Inc. and certain of its affiliates with certain regulators,
     including the New York Attorney General's Office, the SEC and the Colorado
     Attorney General's Office (the settlement) arising out of certain market
     timing and unfair pricing allegations made against Invesco Aim Advisors,
     Inc. and certain of its affiliates, Invesco Aim Advisors, Inc. and certain
     of its affiliates agreed, among other things, to disclose certain
     hypothetical information regarding investment and expense information to
     fund



James O'Connor
April 22, 2009
Page 2


     shareholders. The chart below is intended to reflect the annual and
     cumulative impact of the fund's expenses, including investment advisory
     fees and other fund costs, on the fund's return over a 10-year period. The
     example reflects the following:

     We do not believe we otherwise have the authority to further amend this
language without bringing all parties back to the table to collectively revise
the disclosure.

Staff's Comment:

2.   FUND MANAGEMENT: THE ADVISORS

     Include additional information in the disclosure about the market timing
     and fair value pricing related litigation and regulatory action, including
     an udate on the current state of the litigation and the settlement amount
     reached with the NYAG and the Commission. Consider too removing the risk
     factor indicating that shareholders may react by redeeming their investment
     in the fund.

Response:

     The Registrant believes that the disclosure is adequate; though will take
the comment under advisement in considering disclosure updates for the
prospectuses of all 102 AIM Funds in which this disclosure appears. All updated
information regarding the current status of the litigation and settlement
amounts are on page 73--74 of the Statement of Additional Information, which
contains disclosure about Pending Litigation and is cross referenced in the
section highlighted by the Staff. See too Schedule I-1 of the Statement of
Additional Information, which includes the list of all outstanding civil
litigation. We believe that the risk factor referenced in your comment remains
relevant due to the outstanding civil claims against the fund and various
affiliates and, for that reason, prefer to keep this risk disclosure in the
prospectus rather than move it to the SAI. Please note, this language has been
previously reviewed and approved by the Staff in 485(a) filings of this and the
other AIM Funds.

Please do not hesitate to contact me at 713.214.5770 if you have any further
questions.

Very truly yours,


/s/ Melanie Ringold
Melanie Ringold