Invesco DB Commodity Index Tracking Fund (DBC) CORRESP Correspondence with SEC

DB COMMODITY INDEX TRACKING FUND

C/O DB COMMODITY SERVICES LLC

60 WALL STREET

NEW YORK, NEW YORK 10005

January 12, 2006

Michael McTiernan

Special Counsel

Securities and Exchange Commission

Division of Corporation Finance

100 F. Street NE

Mail Stop 4561

Washington, D.C. 20549

Re: DB Commodity Index Tracking Fund (the “Company”)

Pre-Effective Amendment No. 6 to the Registration Statement

on Form S-1 (File No. 333-125325)

Dear Mr. McTiernan:

We hereby request that the effective date for the above-captioned Registration Statement be accelerated so that it will be declared effective under the Securities Act of 1933, as amended, at 9:00 a.m. on Tuesday, January 17, 2006, or as soon thereafter as reasonably practicable.

We hereby acknowledge that:

1. should the Securities and Exchange Commission (the “Commission”), or the staff of the Commission (the “Staff”), acting pursuant to delegated authority, declare this filing effective, it does not foreclose the Commission from taking any action with regard to the filing;

2. the action of the Commission or the Staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Company from its responsibility for the adequacy and accuracy of the disclosure in this filing; and

3. the Company may not assert this action as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

Very truly yours,

DB COMMODITY INDEX TRACKING FUND		DEUTSCHE BANK SECURITIES INC.
By:	DB Commodity Services LLC, its Managing Owner
By:	/s/ Kevin Rich	By:	/s/ Frank Comas
	Name: Kevin Rich Title:   Director and Chief Executive Officer		Name: Frank Comas Title:   Managing Director
By:	/s/ Noam Berk
	Name: Noam Berk Title:   Treasurer