CORRESP 4 filename4.txt SEWARD & KISSEL LLP 1200 G Street, N.W. Washington, DC 20005 Telephone: (202) 737-8833 Facsimile: (202) 737-5184 www.sewkis.com February 26, 2009 VIA EDGAR Office of Insurance Products Division of Investment Management Securities and Exchange Commission 100 F Street, N.E. Washington, DC 20549 Re: AllianceBernstein Variable Products Series Fund, Inc. - AllianceBernstein Global Thematic Growth Portfolio File Nos. 33-18647 and 811-5398 ------------------------------- Dear Sir or Madame: Pursuant to Rule 485(a) under the Securities Act of 1933 (the "1933 Act"), we are filing Post-Effective Amendment No. 48 under the 1933 Act and Amendment No. 49 under the Investment Company Act of 1940 to the Registration Statement on Form N-1A of AllianceBernstein Global Thematic Growth Portfolio (formerly, AllianceBernstein Global Technology Portfolio) (the "Portfolio"), a series of AllianceBernstein Variable Products Series Fund, Inc. (the "Fund"). We are making this filing for the purpose of revising the risk/return summary, principal risks disclosure, disclosure responding to Item 4 of Form N-1A and disclosure concerning certain of the Portfolio's non-fundamental investment policies so that the disclosure reflects the changes to the Portfolio's name and policies recently approved by the Fund's Board of Directors. Disclosure other than that described above contained in the Portfolio's prospectus and statement of additional information (except for updating financial and performance information) is the same as the disclosure previously reviewed by the staff of the Securities and Exchange Commission. Accordingly, we ask for selective review of Post-Effective Amendment No. 48. If you have any questions regarding the enclosed, please do not hesitate to contact the undersigned at (202) 737-8833. Sincerely, /s/Young Seo ---------------------- Young Seo, Esq. Seward & Kissel LLP Attachment SK 00250 0292 968994v1