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                                                             ALEXANDER D. PHUNG
                                                                      ASSOCIATE
                                                                 (612) 492-6172
                                                          PHUNG.ALEX@DORSEY.COM


July 31, 2009


 VIA EDGAR

 Securities and Exchange Commission
 Division of Investment Management
 Office of Insurance Products
 100 F Street NE
 Washington, DC 20549

      Re:   Preliminary Proxy Statement for Special Joint Meeting of
            Shareholders of the Allianz Variable Insurance Products Trust and
            the Allianz Variable Insurance Products Fund of Funds Trust (each, a
            "Trust")


Ladies and Gentlemen:

            Enclosed for filing via EDGAR is a preliminary proxy statement to be
used by the board of trustees in soliciting voting instructions for a special
joint meeting of shareholders of the funds of each Trust.  Also enclosed is the
voting instruction form.

            At the meeting, the shareholders can vote on two proposals: (a) to
elect individuals to serve on the board of trustees, and (b) to ratify the
board's selection of KPMG LLP to serve as each Trust's independent auditor.  The
board of trustees of each Trust unanimously recommends a vote FOR both
proposals.

            Please contact me at (612) 492-6172 if you have any comments or
questions concerning this filing.  Thank you for your assistance.


                                     Best regards,

                                     /s/ Alexander D. Phung


                                     Alexander D. Phung