Erik Nelson, Sr. Securities Counsel
Allianz Investment Management LLC
5701 Golden Hills Drive
Minneapolis, MN  55416-1297
Telephone: (763) 765-7453

June 24, 2009

VIA EDGAR

Securities and Exchange Commission
Division of Investment Management
Office of Insurance Products
100 F Street NE
Washington, DC 20549

  Re:    Registration Statement on Form N-14 for Combination of Certain
         Series of the Allianz Variable Insurance Products Trust (the "VIP
         Trust") (SEC File Nos. 333-83423 and 811-09491) with and into
         Corresponding Series of the VIP Trust, and of the Allianz Variable
         Insurance Products Fund of Funds Trust (the "Fund of Funds
         Trust")(SEC File Nos. 333-119867 and 811-21624)

Dear Sir/Madam:

          Accompanying this letter for filing is one copy of the Trust's
Registration Statement on Form N-14. This registration statement relates to the
proposed combination of certain series of the VIP Trust with and into
corresponding series of the VIP Trust and the Fund of Funds Trust. Exhibits not
included in this filing will be filed by amendment. Please note that the
registration statement contains eight separate proxy statement/prospectuses.

         Pursuant to Form N-14, General Instruction B, and Rule 24f-2, no filing
fee is due upon the filing of this registration statement.

         Pursuant to Rule 488 under the Securities Act of 1933, as amended, this
registration statement will become effective automatically on the thirtieth day
after the date upon which it is filed.

         Please contact me at the above telephone number or e-mail address if
you have any questions concerning this filing. Thanks you for your assistance.


Sincerely,

Allianz Variable Insurance Products Trust
Allianz Variable Insurance Products Fund of Funds Trust



By: /s/ Erik Nelson
  _________________________________________