SEWARD & KISSEL LLP
                               1200 G Street, N.W.
                              Washington, DC 20005

                            Telephone: (202) 737-8833
                            Facsimile: (202) 737-5184
                                 www.sewkis.com

                                                          April 28, 2009


Securities and Exchange Commission
100 F Street, N.E.
Washington, DC 20549

        Re:    AllianceBernstein Variable Products Series Fund, Inc.
               File Nos. 33-18647 and 811-5398


Dear Sir or Madam:

          Attached herewith please find Post-Effective Amendment No. 49 under
the Securities Act of 1933 (the "1933 Act") and Amendment No. 50 under the
Investment Company Act of 1940 to the Registration Statement on Form N-1A of
AllianceBernstein Variable Products Series Fund, Inc. (the "Amendment"). The
Amendment is filed pursuant to paragraph (b) of Rule 485 under the 1933 Act and
is marked to show changes in accordance with Rule 310 of Regulation S-T.

          Please call me at the above-referenced number if you have any
questions regarding the attached.


                                                   Sincerely,


                                                   /s/ Young Seo
                                                   --------------
                                                       Young Seo

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