Morgan Stanley Variable Investment Series

522 Fifth Avenue

New York, NY 10036

March 30, 2010

Securities and Exchange Commission

Judiciary Plaza

100 F Street, NE

Washington, D.C.  20549

Attention:  Michael L. Kosoff

Re:Morgan Stanley Variable Investment Series

(File No. 002-82510; 811-03692)

Dear Mr. Kosoff:

In response to your oral comments on March 24, 2010, below please find the fee tables and corresponding footnotes for each portfolio of Morgan Stanley Variable Investment Series.

FEE TABLES:

Aggressive Equity Portfolio

Class X:

Annual Portfolio Operating Expenses
(expenses that you pay each year as a percentage of the value of your investment)

Advisory fee	0.67	%
Distribution and service (12b-1) fees	None
Other expenses	0.35	%
Total annual Portfolio operating expenses	1.02	%

Class Y:

Annual Portfolio Operating Expenses
(expenses that you pay each year as a percentage of the value of your investment)

Advisory fee	0.67	%
Distribution and service (12b-1) fees	0.25	%
Other expenses	0.35	%
Total annual Portfolio operating expenses	1.27	%

Capital Opportunities Portfolio

Class X:

Annual Portfolio Operating Expenses
(expenses that you pay each year as a percentage of the value of your investment)

Advisory fee	0.42	%
Distribution and service (12b-1) fees	None
Other expenses	0.13	%
Total annual Portfolio operating expenses	0.55	%

Class Y:

Annual Portfolio Operating Expenses
(expenses that you pay each year as a percentage of the value of your investment)

Advisory fee	0.42	%
Distribution and service (12b-1) fees	0.25	%
Other expenses	0.13	%
Total annual Portfolio operating expenses	0.80	%

Dividend Growth Portfolio

Class X:

Annual Portfolio Operating Expenses
(expenses that you pay each year as a percentage of the value of your investment)

Advisory fee	0.54	%
Distribution and service (12b-1) fees	None
Other expenses	0.13	%
Total annual Portfolio operating expenses	0.67	%

Class Y:

Annual Portfolio Operating Expenses
(expenses that you pay each year as a percentage of the value of your investment)

Advisory fee	0.54	%
Distribution and service (12b-1) fees	0.25	%
Other expenses	0.13	%
Total annual Portfolio operating expenses	0.92	%

European Equity Portfolio

Class X:

Annual Portfolio Operating Expenses
(expenses that you pay each year as a percentage of the value of your investment)

Advisory fee	0.87	%
Distribution and service (12b-1) fees	None
Other expenses	0.25	%
Total annual Portfolio operating expenses*	1.12	%
Fee waiver and/or expense reimbursement*	0.12	%
Total annual Portfolio operating expenses after fee waiver and/or expense reimbursement*	1.00	%

*The Portfolio’s “Investment Adviser,” Morgan Stanley Investment Advisors Inc., is currently waiving or reimbursing all or a portion of the Portfolio’s advisory fees and/or other expenses (excluding brokerage fees). The fee waivers and/or expense reimbursements are expected to continue (such that the Total annual Portfolio operating expenses after fee waiver and/or expense reimbursement do not exceed those amounts listed above) until such time that the Fund’s Board of Trustees acts to discontinue such waivers and/or reimbursements when it deems such action is appropriate.

Class Y:

Annual Portfolio Operating Expenses
(expenses that you pay each year as a percentage of the value of your investment)

Advisory fee	0.87	%
Distribution and service (12b-1) fees	0.25	%
Other expenses	0.25	%
Total annual Portfolio operating expenses*	1.37	%
Fee waiver and/or expense reimbursement*	0.12	%
Total annual Portfolio operating expenses after fee waiver and/or expense reimbursement*	1.25	%

*The Portfolio’s “Investment Adviser,” Morgan Stanley Investment Advisors Inc., is currently waiving or reimbursing all or a portion of the Portfolio’s advisory fees and/or other expenses (excluding distribution and service (12b-1) fees and brokerage fees). The fee waivers and/or expense reimbursements are expected to continue (such that the Total annual Portfolio operating expenses after fee waiver and/or expense reimbursement do not exceed those amounts listed above) until such time that the Fund’s Board of Trustees acts to discontinue such waivers and/or reimbursements when it deems such action is appropriate.

Global Dividend Growth Portfolio

Class X:

Annual Portfolio Operating Expenses
(expenses that you pay each year as a percentage of the value of your investment)

Advisory fee	0.67	%
Distribution and service (12b-1) fees	None
Other expenses	0.26	%
Total annual Portfolio operating expenses	0.93	%

Class Y:

Annual Portfolio Operating Expenses
(expenses that you pay each year as a percentage of the value of your investment)

Advisory fee	0.67	%
Distribution and service (12b-1) fees	0.25	%
Other expenses	0.26	%
Total annual Portfolio operating expenses	1.18	%

Global Infrastructure Portfolio

Class X:

Annual Portfolio Operating Expenses
(expenses that you pay each year as a percentage of the value of your investment)

Advisory fee	0.57	%
Distribution and service (12b-1) fees	None
Other expenses	0.39	%
Total annual Portfolio operating expenses	0.96	%

Class Y:

Annual Portfolio Operating Expenses
(expenses that you pay each year as a percentage of the value of your investment)

Advisory fee	0.57	%
Distribution and service (12b-1) fees	0.25	%
Other expenses	0.39	%
Total annual Portfolio operating expenses	1.21	%

High Yield Portfolio

Class X:

Annual Portfolio Operating Expenses
(expenses that you pay each year as a percentage of the value of your investment)

Advisory fee	0.42	%
Distribution and service (12b-1) fees	None
Other expenses	1.33	%
Total annual Portfolio operating expenses	1.75	%

Class Y:

Annual Portfolio Operating Expenses
(expenses that you pay each year as a percentage of the value of your investment)

Advisory fee	0.42	%
Distribution and service (12b-1) fees	0.25	%
Other expenses	1.33	%
Total annual Portfolio operating expenses	2.00	%

Income Builder Portfolio

Class X:

Annual Portfolio Operating Expenses
(expenses that you pay each year as a percentage of the value of your investment)

Advisory fee	0.67	%
Distribution and service (12b-1) fees	None
Other expenses	0.35	%
Total annual Portfolio operating expenses	1.02	%

Class Y:

Annual Portfolio Operating Expenses
(expenses that you pay each year as a percentage of the value of your investment)

Advisory fee	0.67	%
Distribution and service (12b-1) fees	0.25	%
Other expenses	0.35	%
Total annual Portfolio operating expenses	1.27	%

Income Plus Portfolio

Class X:

Annual Portfolio Operating Expenses
(expenses that you pay each year as a percentage of the value of your investment)

Advisory fee	0.42	%
Distribution and service (12b-1) fees	None
Other expenses	0.14	%
Total annual Portfolio operating expenses	0.56	%

Class Y:

Annual Portfolio Operating Expenses
(expenses that you pay each year as a percentage of the value of your investment)

Advisory fee	0.42	%
Distribution and service (12b-1) fees	0.25	%
Other expenses	0.14	%
Total annual Portfolio operating expenses	0.81	%

Limited Duration Portfolio

Class X:

Annual Portfolio Operating Expenses
(expenses that you pay each year as a percentage of the value of your investment)

Advisory fee	0.30	%
Distribution and service (12b-1) fees	None
Other expenses	0.19	%
Total annual Portfolio operating expenses	0.49	%

Class Y:

Annual Portfolio Operating Expenses
(expenses that you pay each year as a percentage of the value of your investment)

Advisory fee	0.30	%
Distribution and service (12b-1) fees	0.25	%
Other expenses	0.19	%
Total annual Portfolio operating expenses	0.74	%

Money Market Portfolio

Class X:

Annual Portfolio Operating Expenses
(expenses that you pay each year as a percentage of the value of your investment)

Advisory fee	0.45	%
Distribution and service (12b-1) fees	None
Other expenses	0.11	%
Total annual Portfolio operating expenses*	0.56	%
Fee waiver and/or expense reimbursement*	0.19	%
Total annual Portfolio operating expenses after fee waiver and/or expense reimbursement*	0.37	%

*The Portfolio’s “Investment Adviser,” Morgan Stanley Investment Advisors Inc., is currently waiving or reimbursing all or a portion of the Portfolio’s advisory fees and/or other expenses to the extent that total expenses exceed total income on a daily basis. The fee waivers and/or expense reimbursements are expected to continue until such time as the Fund’s Board of Trustees acts to discontinue all or a portion of such waivers and/or expense reimbursements when it deems such action is appropriate.

Class Y:

Annual Portfolio Operating Expenses
(expenses that you pay each year as a percentage of the value of your investment)

Advisory fee	0.45	%
Distribution and service (12b-1) fees	0.25	%
Other expenses	0.11	%
Total annual Portfolio operating expenses*	0.81	%
Fee waiver and/or expense reimbursement*	0.43	%
Total annual Portfolio operating expenses after fee waiver and/or expense reimbursement*	0.38	%

*The Portfolio’s “Investment Adviser,” Morgan Stanley Investment Advisors Inc., is currently waiving or reimbursing all or a portion of the Portfolio’s advisory fees and/or other expenses to the extent that total expenses exceed total income on a daily basis. The fee waivers and/or expense reimbursements are expected to continue until such time as the Fund’s Board of Trustees acts to discontinue all or a portion of such waivers and/or expense reimbursements when it deems such action is appropriate.

S&P 500 Index Portfolio

Class X:

Annual Portfolio Operating Expenses
(expenses that you pay each year as a percentage of the value of your investment)

Advisory fee	0.12	%
Distribution and service (12b-1) fees	None
Other expenses	0.16	%
Total annual Portfolio operating expenses	0.28	%

Class Y:

Annual Portfolio Operating Expenses
(expenses that you pay each year as a percentage of the value of your investment)

Advisory fee	0.12	%
Distribution and service (12b-1) fees	0.25	%
Other expenses	0.16	%
Total annual Portfolio operating expenses	0.53	%

Strategist Portfolio

Class X:

Annual Portfolio Operating Expenses
(expenses that you pay each year as a percentage of the value of your investment)

Advisory fee	0.42	%
Distribution and service (12b-1) fees	None
Other expenses	0.16	%
Total annual Portfolio operating expenses	0.58	%

Class Y:

Annual Portfolio Operating Expenses
(expenses that you pay each year as a percentage of the value of your investment)

Advisory fee	0.42	%
Distribution and service (12b-1) fees	0.25	%
Other expenses	0.16	%
Total annual Portfolio operating expenses	0.83	%

If you would like to discuss this matter in further detail or if you have any questions, please feel free to contact me at (212) 296-6989 (tel) or (646) 290.2042 (fax).  Thank you.

Best regards,

/s/ Sheri Schreck

Sheri Schreck