[Invesco Letterhead]

November 2, 2018

VIA EDGAR

U.S. Securities and Exchange Commission

Division of Investment Management

Disclosure Review and Accounting Office

100 F Street NE

Washington, DC 20549

Re: AIM International Mutual Funds (Invesco International Mutual Funds)

CIK No. 0000880859

Ladies and Gentlemen:

On behalf of AIM International Mutual Funds (Invesco International Mutual Funds) (the “Registrant”), attached herewith for filing pursuant to the provisions of the Securities Act of 1933, as amended (“1933 Act”), and Rule 485(a)(2) promulgated thereunder, and the Investment Company Act of 1940, as amended (“1940 Act”), is the electronic version of Post-Effective Amendment No. 78/80 (the “Amendment”) to the Registrant’s registration statement on Form N-1A.

This Amendment is being filed in order to register new series of the Registrant as part of Invesco Ltd.’s proposed acquisition of OppenheimerFunds, Inc. and its subsidiaries. The new funds, listed on Appendix A attached to this letter under AIM International Mutual Funds (Invesco International Mutual Funds) (the “New Funds”), are shell series portfolios intended to acquire the assets of the corresponding Oppenheimer funds, also listed on Appendix A (the “Predecessor Funds”), pending necessary approvals including shareholder approval of applicable agreements and plans of reorganization.

Pursuant to Release No. 13768 under the 1940 Act and IM Guidance Update No. 2016-06 released by the U.S. Securities and Exchange Commission (the “Commission”) on December 15, 2016 (the “Guidance”), the Registrant believes that portions of the Amendment may be eligible for selective review because they are not substantially different from the disclosure previously reviewed by the Commission. In particular, we respectfully request that the Staff selectively review the Amendment because the New Funds contain materially the same investment objective, principal investment strategies and principal risk disclosure as it pertains to the corresponding Predecessor Funds, which disclosure was Previously reviewed by the Staff in connection with Rule 485(a) filings made by such Predecessor Funds, except for the following:

• For New Funds that correspond to Predecessor Funds with 80% policies, we have added the following language to such 80% policies as permitted by Rule 35d-1 and consistent with other Invesco Funds: “and in derivatives and other instruments that have economic characteristics similar to such securities.”

• We have adopted the standard SAI fundamental and non-fundamental investment restriction language of existing Invesco Funds for consistency across the complex.

It is anticipated that the New Funds will retain the portfolio management teams of the Predecessor Funds and as such, the New Funds are expected to be managed in substantially the same manner as the Predecessor Funds.

Additionally, the Staff Previously reviewed the Registrant’s registration statement in connection with Rule 485(a) filings for AIM Counselor Series Trust (Invesco Counselor Series Trust) filed on July 10, 2018 and for AIM Investment Funds (Invesco Investment Funds) on December 27, 2017. The provisions in the Registrant’s registration statement in such filings regarding the features of the share classes offered by the Registrant’s series, including provisions related to the purchase, exchange and sale of fund shares and shareholder eligibility (the foregoing are found in the section of the Registrant’s prospectuses labeled “Shareholder Account Information” and the Registrant’s SAI labeled “Appendix L”) are materially the same as those in the Amendment. The Registrant believes that such portions of the Amendment may be eligible for selective review because they are not substantially different from the disclosure previously reviewed by the Commission

Please send copies of all correspondence with respect to the Amendment to the undersigned or contact me at (713) 214-7888.

Very truly yours,

/s/ Peter Davidson

Peter Davidson

Assistant General Counsel

cc:   Jaea Hahn

Appendix A

Oppenheimer Registrant (Oppenheimer Fund Name) Oppenheimer Portfolio Series Active Allocation Fund Conservative Investor Fund Growth Investor Fund (formerly, Equity Investor Fund)	Invesco Registrant (Invesco Fund Name) AIM Growth Series (Invesco Growth Series) Invesco Oppenheimer Portfolio Series: Active Allocation Fund Invesco Oppenheimer Portfolio Series: Conservative Investor Fund Invesco Oppenheimer Portfolio Series: Growth Investor Fund
Moderate Investor Fund Oppenheimer International Diversified Fund Oppenheimer International Diversified Fund Oppenheimer Main Street Mid Cap Fund® Oppenheimer Main Street Mid Cap Fund® Oppenheimer Main Street Small Cap Fund® Oppenheimer Main Street Small Cap Fund® Oppenheimer Quest for Value Funds Oppenheimer Mid Cap Value Fund Oppenheimer Master Event-Linked Bond Fund, LLC Oppenheimer Master Event-Linked Bond Fund, LLC	Invesco Oppenheimer Portfolio Series: Moderate Investor Fund AIM Growth Series (Invesco Growth Series) Invesco Oppenheimer International Diversified Fund AIM Growth Series (Invesco Growth Series) Invesco Oppenheimer Main Street Mid Cap Fund® AIM Growth Series (Invesco Growth Series) Invesco Oppenheimer Main Street Small Cap Fund® AIM Growth Series (Invesco Growth Series) Invesco Oppenheimer Mid Cap Value Fund AIM Growth Series (Invesco Growth Series) Invesco Oppenheimer Master Event-Linked Bond Fund
Oppenheimer Capital Appreciation Fund Oppenheimer Capital Appreciation Fund Oppenheimer Discovery Fund Oppenheimer Discovery Fund Oppenheimer Equity Income Fund Oppenheimer Equity Income Fund Oppenheimer Real Estate Fund Oppenheimer Real Estate Fund Oppenheimer Rochester Short Duration High Yield Municipal Fund Oppenheimer Rochester® Short Duration High Yield Municipal Fund Oppenheimer Senior Floating Rate Fund Oppenheimer Senior Floating Rate Fund Oppenheimer Senior Floating Rate Plus Fund Oppenheimer Senior Floating Rate Plus Fund Oppenheimer Short Term Municipal Fund Oppenheimer Short Term Municipal Fund Oppenheimer Master Loan Fund, LLC Oppenheimer Master Loan Fund, LLC	AIM Counselor Series Trust (Invesco Counselor Series Trust) Invesco Oppenheimer Capital Appreciation Fund AIM Counselor Series Trust (Invesco Counselor Series Trust) Invesco Oppenheimer Discovery Fund AIM Counselor Series Trust (Invesco Counselor Series Trust) Invesco Oppenheimer Equity Income Fund AIM Counselor Series Trust (Invesco Counselor Series Trust) Invesco Oppenheimer Real Estate Fund AIM Counselor Series Trust (Invesco Counselor Series Trust) Invesco Oppenheimer Rochester® Short Duration High Yield Municipal Fund AIM Counselor Series Trust (Invesco Counselor Series Trust) Invesco Oppenheimer Senior Floating Rate Fund AIM Counselor Series Trust (Invesco Counselor Series Trust) Invesco Oppenheimer Senior Floating Rate Plus Fund AIM Counselor Series Trust (Invesco Counselor Series Trust) Invesco Oppenheimer Short Term Municipal Fund AIM Counselor Series Trust (Invesco Counselor Series Trust) Invesco Oppenheimer Master Loan Fund
Oppenheimer Capital Income Fund Oppenheimer Capital Income Fund Oppenheimer Developing Markets Fund Oppenheimer Developing Markets Fund Oppenheimer Discovery Mid Cap Growth Fund Oppenheimer Discovery Mid Cap Growth Fund Oppenheimer Emerging Markets Innovators Fund Oppenheimer Emerging Markets Innovators Fund Oppenheimer Emerging Markets Local Debt Fund Oppenheimer Emerging Markets Local Debt Fund Oppenheimer Quest for Value Funds Oppenheimer Global Allocation Fund Oppenheimer Fundamental Alternatives Fund Oppenheimer Global Multi-Asset Income Fund Oppenheimer Global Multi-Asset Income Fund Oppenheimer Global Strategic Income Fund Oppenheimer Global Strategic Income Fund Oppenheimer Integrity Funds Oppenheimer Global Unconstrained Bond Fund Oppenheimer Preferred Securities and Income Fund Oppenheimer Total Return Bond Fund Oppenheimer International Bond Fund Oppenheimer International Bond Fund Oppenheimer Macquarie Global Infrastructure Fund Oppenheimer Macquarie Global Infrastructure Fund	AIM Investment Funds (Invesco Investment Funds) Invesco Oppenheimer Capital Income Fund AIM Investment Funds (Invesco Investment Funds) Invesco Oppenheimer Developing Markets Fund AIM Investment Funds (Invesco Investment Funds) Invesco Oppenheimer Discovery Mid Cap Growth Fund AIM Investment Funds (Invesco Investment Funds) Invesco Oppenheimer Emerging Markets Innovators Fund AIM Investment Funds (Invesco Investment Funds) Invesco Oppenheimer Emerging Markets Local Debt Fund AIM Investment Funds (Invesco Investment Funds) Invesco Oppenheimer Global Allocation Fund Invesco Oppenheimer Fundamental Alternatives Fund AIM Investment Funds (Invesco Investment Funds) Invesco Oppenheimer Global Multi-Asset Income Fund AIM Investment Funds (Invesco Investment Funds) Invesco Oppenheimer Global Strategic Income Fund AIM Investment Funds (Invesco Investment Funds) Invesco Oppenheimer Global Unconstrained Bond Fund Invesco Oppenheimer Preferred Securities and Income Fund Invesco Oppenheimer Total Return Bond Fund AIM Investment Funds (Invesco Investment Funds) Invesco Oppenheimer International Bond Fund AIM Investment Funds (Invesco Investment Funds) Invesco Oppenheimer Macquarie Global Infrastructure Fund

Oppenheimer SteelPath MLP Funds Trust Oppenheimer SteelPath MLP Alpha Fund Oppenheimer Steelpath MLP Alpha Plus Fund Oppenheimer SteelPath MLP Income Fund Oppenheimer SteelPath MLP Select 40 Fund Oppenheimer SteelPath Panoramic Fund Oppenheimer SteelPath Panoramic Fund OFI SteelPath Series Trust Oppenheimer SteelPath MLP & Energy Infrastructure Fund	AIM Investment Funds (Invesco Investment Funds) Invesco Oppenheimer SteelPath MLP Alpha Fund Invesco Oppenheimer Steelpath MLP Alpha Plus Fund Invesco Oppenheimer SteelPath MLP Income Fund Invesco Oppenheimer SteelPath MLP Select 40 Fund AIM Investment Funds (Invesco Investment Funds) Invesco Oppenheimer SteelPath Panoramic Fund AIM Investment Funds (Invesco Investment Funds) Invesco Oppenheimer SteelPath MLP & Energy Infrastructure Fund
Oppenheimer Intermediate Income Fund (formerly, Oppenheimer Corporate Bond Fund) Oppenheimer Intermediate Income Fund (formerly, Oppenheimer Corporate Bond Fund) Oppenheimer Global High Yield Fund Oppenheimer Global High Yield Fund Oppenheimer Government Cash Reserves Oppenheimer Government Cash Reserves Oppenheimer Government Money Market Fund Oppenheimer Government Money Market Fund Oppenheimer Limited-Term Bond Fund Oppenheimer Limited-Term Bond Fund Oppenheimer Limited-Term Government Fund Oppenheimer Limited-Term Government Fund Oppenheimer Ultra-Short Duration Fund Oppenheimer Ultra-Short Duration Fund Oppenheimer Master Inflation Protected Securities Fund, LLC Oppenheimer Master Inflation Protected Securities Fund, LLC	AIM Investment Securities Funds (Invesco Investment Securities Funds) Invesco Oppenheimer Intermediate Income Fund AIM Investment Securities Funds (Invesco Investment Securities Funds) Invesco Oppenheimer Global High Yield Fund AIM Investment Securities Funds (Invesco Investment Securities Funds) Invesco Oppenheimer Government Cash Reserves Fund AIM Investment Securities Funds (Invesco Investment Securities Funds) Invesco Oppenheimer Government Money Market Fund AIM Investment Securities Funds (Invesco Investment Securities Funds) Invesco Oppenheimer Limited-Term Bond Fund AIM Investment Securities Funds (Invesco Investment Securities Funds) Invesco Oppenheimer Limited-Term Government Fund AIM Investment Securities Funds (Invesco Investment Securities Funds) Invesco Oppenheimer Ultra-Short Duration Fund AIM Investment Securities Funds (Invesco Investment Securities Funds) Invesco Oppenheimer Master Inflation Protected Securities Fund
Oppenheimer Dividend Opportunity Fund Oppenheimer Dividend Opportunity Fund Oppenheimer Main Street Funds® Oppenheimer Main Street Fund® Oppenheimer Main Street All Cap Fund® Oppenheimer Main Street All Cap Fund® Oppenheimer Rising Dividends Fund Oppenheimer Rising Dividends Fund	AIM Equity Funds (Invesco Equity Funds) Invesco Oppenheimer Dividend Opportunity Fund AIM Equity Funds (Invesco Equity Funds) Invesco Oppenheimer Main Street Fund® AIM Equity Funds (Invesco Equity Funds) Invesco Oppenheimer Main Street All Cap Fund® AIM Equity Funds (Invesco Equity Funds) Invesco Oppenheimer Rising Dividends Fund
Oppenheimer Global Fund Oppenheimer Global Fund Oppenheimer Global Focus Fund Oppenheimer Global Focus Fund Oppenheimer Global Multi-Asset Growth Fund Oppenheimer Global Multi-Asset Growth Fund Oppenheimer Global Opportunities Fund Oppenheimer Global Opportunities Fund Oppenheimer International Equity Fund Oppenheimer International Equity Fund Oppenheimer International Growth Fund Oppenheimer International Growth Fund Oppenheimer International Small-Mid Company Fund Oppenheimer International Small-Mid Company Fund	AIM International Mutual Funds (Invesco International Mutual Funds) Invesco Oppenheimer Global Fund AIM International Mutual Funds (Invesco International Mutual Funds) Invesco Oppenheimer Global Focus Fund AIM International Mutual Funds (Invesco International Mutual Funds) Invesco Oppenheimer Global Multi-Asset Growth Fund AIM International Mutual Funds (Invesco International Mutual Funds) Invesco Oppenheimer Global Opportunities Fund AIM International Mutual Funds (Invesco International Mutual Funds) Invesco Oppenheimer International Equity Fund AIM International Mutual Funds (Invesco International Mutual Funds) Invesco Oppenheimer International Growth Fund AIM International Mutual Funds (Invesco International Mutual Funds) Invesco Oppenheimer International Small-Mid Company Fund
Oppenheimer Gold & Special Minerals Fund Oppenheimer Gold & Special Minerals Fund Oppenheimer Small Cap Value Fund Oppenheimer Small Cap Value Fund Oppenheimer Series Fund Oppenheimer Value Fund OFI Funds Trust OFI Pictet Global Environmental Solutions Fund	AIM Sector Funds (Invesco Sector Funds) Invesco Oppenheimer Gold & Special Minerals Fund AIM Sector Funds (Invesco Sector Funds) Invesco Oppenheimer Small Cap Value Fund AIM Sector Funds (Invesco Sector Funds) Invesco Oppenheimer Value Fund AIM Sector Funds (Invesco Sector Funds) Invesco OFI Pictet Global Environmental Solutions Fund
Oppenheimer Institutional Government Money Market Fund Oppenheimer Institutional Government Money Market Fund	Short-Term Investments Trust Invesco Oppenheimer Institutional Government Money Market Fund

Oppenheimer Intermediate Term Municipal Fund Oppenheimer Intermediate Term Municipal Fund Oppenheimer Rochester® AMT-Free Municipal Fund Oppenheimer Rochester® AMT-Free Municipal Fund Oppenheimer Rochester® AMT-Free New York Municipal Fund Oppenheimer Rochester® AMT-Free New York Municipal Fund Oppenheimer Rochester® California Municipal Fund Oppenheimer Rochester® California Municipal Fund Oppenheimer Rochester® Fund Municipals Oppenheimer Rochester® Fund Municipals Oppenheimer Multi-State Municipal Trust Oppenheimer Rochester® High Yield Municipal Fund Oppenheimer Rochester® New Jersey Municipal Fund Oppenheimer Rochester® Pennsylvania Municipal Fund Oppenheimer Rochester® Limited Term California Municipal Fund Oppenheimer Rochester® Limited Term California Municipal Fund Rochester® Portfolio Series Oppenheimer Rochester® Limited Term New York Municipal Fund Oppenheimer Municipal Fund Oppenheimer Municipal Fund

AIM Tax-Exempt Funds (Invesco Tax-Exempt Funds) Invesco Oppenheimer Intermediate Term Municipal Fund AIM Tax-Exempt Funds (Invesco Tax-Exempt Funds) Invesco Oppenheimer Rochester® AMT-Free Municipal Fund AIM Tax-Exempt Funds (Invesco Tax-Exempt Funds) Invesco Oppenheimer Rochester® AMT-Free New York Municipal Fund AIM Tax-Exempt Funds (Invesco Tax-Exempt Funds) Invesco Oppenheimer Rochester® California Municipal Fund AIM Tax-Exempt Funds (Invesco Tax-Exempt Funds) Invesco Oppenheimer Rochester® Municipals Fund AIM Tax-Exempt Funds (Invesco Tax-Exempt Funds) Invesco Oppenheimer Rochester® High Yield Municipal Fund Invesco Oppenheimer Rochester® New Jersey Municipal Fund Invesco Oppenheimer Rochester® Pennsylvania Municipal Fund AIM Tax-Exempt Funds (Invesco Tax-Exempt Funds) Invesco Oppenheimer Rochester® Limited Term California Municipal Fund AIM Tax-Exempt Funds (Invesco Tax-Exempt Funds) Invesco Oppenheimer Rochester® Limited Term New York Municipal Fund AIM Tax-Exempt Funds (Invesco Tax-Exempt Funds) Invesco Oppenheimer Municipal Fund

Oppenheimer Variable Account Funds Oppenheimer Capital Appreciation Fund/VA Oppenheimer Conservative Balanced Fund/VA Oppenheimer Discovery Mid Cap Growth Fund/VA Oppenheimer Global Multi-Alternatives Fund/VA Oppenheimer Global Fund/VA Oppenheimer Global Strategic Income Fund/VA Oppenheimer International Growth Fund/VA Oppenheimer Main Street Fund/VA® Oppenheimer Main Street Small Cap Fund/VA® Oppenheimer Total Return Bond Fund/VA Oppenheimer Government Money Fund/VA

AIM Variable Insurance Funds (Invesco Variable Insurance Funds) Invesco Oppenheimer V.I. Capital Appreciation Fund Invesco Oppenheimer V.I. Conservative Balanced Fund Invesco Oppenheimer V.I. Discovery Mid Cap Growth Fund Invesco Oppenheimer V.I. Global Multi-Alternatives Fund Invesco Oppenheimer V.I. Global Fund Invesco Oppenheimer V.I. Global Strategic Income Fund Invesco Oppenheimer V.I. International Growth Fund Invesco Oppenheimer V.I. Main Street Fund® Invesco Oppenheimer V.I. Main Street Small Cap Fund® Invesco Oppenheimer V.I. Total Return Bond Fund Invesco Oppenheimer V.I. Government Money Fund