COVER 7 filename7.txt Erik Nelson, Sr. Securities Counsel Allianz Investment Management LLC 5701 Golden Hills Drive Minneapolis, MN 55416-1297 Telephone: (763) 765-7453 August 3, 2009 VIA EDGAR Securities and Exchange Commission Division of Investment Management Office of Insurance Products 100 F Street NE Washington, DC 20549 Re: Pre-Effective Amendment No. 1 to the Registration Statements on Form N-14 for Combination of Certain Series of the Allianz Variable Insurance Products Trust (the "VIP Trust") (SEC File Nos. 333-160351 and 811-09491) with and into Corresponding Series of the VIP Trust, and of the Allianz Variable Insurance Products Fund of Funds Trust (the "Fund of Funds Trust")(SEC File Nos. 333-160352 and 811-21624) Dear Sir/Madam: Accompanying this letter for filing is Pre-Effective Amendment No. 1 to the Registration Statements on Form N-14. This registration statements relate to the proposed combination of certain series of the VIP Trust with and into corresponding series of the VIP Trust and the Fund of Funds Trust. Also included in Pre-Effective Amendment No. 1 are all required exhibits and requests for acceleration from the trust and Distributor, Allianz Life Financial Services, LLC. Please note that the registration statement contains eight separate proxy statement/prospectuses. The Registrants acknowledge that the Registrants are responsible for the adequacy and accuracy of the disclosure in the filing. Staff comments on the filing and changes to the filing following staff comments do not foreclose the Commission from taking an action with respect to the filing and do not relieve the Registrants from their full responsibility for the adequacy and accuracy of the disclosure in the filing. The Registrants understand that they cannot raise the fact that the staff reviewed the filing as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. Please contact me at the above telephone number or e-mail address if you have any questions concerning this filing. Thanks you for your assistance. Sincerely, Allianz Variable Insurance Products Trust Allianz Variable Insurance Products Fund of Funds Trust By: /s/ Erik Nelson _________________________________________