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

April 27, 2010

VIA EDGAR

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

Re: Post-Effective Amendment No. 28 to Registration Statement on Form N-1A
    Allianz Variable Insurance Products Trust
    File Nos. 333-83423 and 811-09491
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Dear Sir/Madam:

Enclosed for filing please find Post-Effective Amendment No. 28 to Form N-1A for
the above-referenced Registrant. The purpose of this filing is to update
financial information and disclosure to the prospectus and SAI, based on
comments received by the staff, describing the availability of new investment
options being added to the trust and to add new summary disclosure pursuant to
revised Form N-1A. This post-effective amendment also includes a letter
responding to additional staff comments provided by telephone on April 14, 2010.

Manually executed signature pages and consents have been executed prior to the
time of this electronic filing and will be retained by the Company for five
years.

I hereby represent that the enclosed Post-Effective Amendment does not contain
disclosure which would render it ineligible to become effective pursuant to
Securities Act Rule 485(b)

If you  have  any  questions  or  comments,  please  feel  free to  contact  the
undersigned.


Sincerely,

Allianz Variable Insurance Products Trust


By: /s/ Erik Nelson
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