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                   August 26, 2021

       Anna Paglia
       Chief Executive Officer
       Invesco DB Commodity Index Tracking Fund
       c/o Invesco Capital Management LLC
       3500 Lacey Road, Suite 700
       Downers Grove, IL 60515

                                                        Re: Invesco DB
Commodity Index Tracking Fund
                                                            Registration
Statement on Form S-3
                                                            Filed August 25,
2021
                                                            File No. 333-259058

       Dear Ms. Paglia:

              This is to advise you that we have not reviewed and will not
review your registration
       statement.

               Please refer to Rules 460 and 461 regarding requests for
acceleration. We remind you
       that the company and its management are responsible for the accuracy and
adequacy of their
       disclosures, notwithstanding any review, comments, action or absence of
action by the staff.

               Please contact Sonia Bednarowski at 202-551-3666 or Justin
Dobbie, Legal Branch
       Chief, at 202-551-3469 with any questions.




                   Sincerely,


                   Division of Corporation Finance

                   Office of Finance