INVESTMENT MANAGERS SERIES TRUST

803 W. Michigan Street

Milwaukee, Wisconsin  53233

April 10, 2013

Securities and Exchange Commission

100 F Street, NE

Washington, DC 20549

Attention:  Division of Investment Management

Re: Investment Managers Series Trust  (the “Trust”)

File Nos. 333-122901 and 811-21719

on behalf of the WCM Focused Emerging Markets Fund and the WCM Focused Global Growth Fund

The Trust is filing Post-Effective Amendment No. 339 to its Registration Statement under Rule 485(a)(2) to create the new series, WCM Focused Emerging Markets Fund and the WCM Focused Global Growth Fund.

Please direct your comments to the undersigned at (626) 914-1041.  Thank you.

Sincerely,

/s/Rita Dam

Rita Dam

Investment Managers Series Trust

Treasurer