VIA EDGAR

United States Securities and Exchange Commission

Division of Corporation Finance

Washington, D.C. 20549

August 26, 2021

Re: Invesco DB Commodity Index Tracking Fund

Registration Statement on Form S-3 (Registration No. 333-259058)

Ladies and Gentlemen:

Pursuant to Rule 461 under the Securities Act of 1933, as amended, Invesco DB Commodity Index Tracking Fund hereby requests acceleration of the effective date of the Registration Statement on Form S-3 (Registration No. 333-259058), so that it becomes effective at 4:00 p.m., Eastern Time, on August 27, 2021, or as soon as practicable thereafter.

Invesco DB Commodity Index Tracking Fund
By:	Invesco Capital Management LLC, its Managing Owner
	By:	*
		Name: Anna Paglia
		Title: Principal Executive Officer

*By:	/s/ Adam Henkel
	Name: Adam Henkel
	Title: Attorney-in-fact