1900 K Street, NW Washington, DC 20006-1110 +1 202 261 3300 Main +1 202 261 3333 Fax www.dechert.com     ERIC D. SIMANEK   eric.simanek@dechert.com +1 202 261 3424 Direct +1 202 261 3048 Fax

February 13, 2014

VIA EDGAR

Filing Desk

Securities and Exchange Commission

Office of Filings and Information Services

Branch of Registrations and Examinations

Mail Stop 0-25

100 F Street, N.E.

Washington, D.C. 20549

Re:	Goldman Sachs Variable Insurance Trust (the “Registrant”)
	File Nos. 333-35883 and 811-08361
	Post-Effective Amendment No. 42 (the “Amendment”) to the Registration Statement on Form N-1A

Ladies and Gentlemen:

On behalf of the Registrant, electronically transmitted for filing pursuant to Rule 485(a) under the Securities Act of 1933, as amended (“1933 Act”), is Post-Effective Amendment No. 42 to the Registrant’s registration statement on Form N-1A (“Registration Statement”) under the 1933 Act. This Registration Statement is being filed solely for the purpose of registering Advisor Shares of Goldman Sachs Multi-Strategy Alternatives Portfolio (the “Portfolio”). Service Shares and Institutional Shares of the Fund were registered in Post-Effective Amendment No. 40, filed on January 3, 2014. The Securities and Exchange Commission Staff has not yet provided comments in connection with Post-Effective Amendment No. 40.

No fee is required in connection with this filing. Please direct any questions concerning the filing to the undersigned at 202.261.3424.

Very truly yours,

/s/ Eric D. Simanek

Eric D. Simanek