VIA EDGAR
November 5, 2019
U.S. Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, D.C. 20549
Attention: Ms. Erin Purnell
| Re: | Invesco DB Energy Fund |
| | Request for Withdrawal of Post-Effective Amendment No. 1 to the Registration Statement on Form S-1 (SEC Accession No. 0001193125-19-281757) Filed on November 1, 2019 |
Ladies and Gentlemen:
On November 1, 2019, Invesco DB Multi-Sector Commodity Trust (the “Trust”) and Invesco DB Energy Fund (the “Fund,” and together with the Trust, the “Co-Registrants”) filed Post-Effective Amendment No. 1 (the “Post-Effective Amendment”) to the Registration Statement on Form S-1 (SEC Accession No. 0001193125-19-281757).
The Post-Effective Amendment was inadvertently tagged in EDGAR with the incorrect submission type. Consequently, pursuant to Rule 477 under the Securities Act of 1933, as amended, the Registrant respectfully requests the immediate withdrawal of the Post-Effective Amendment filed with the Securities and Exchange Commission (the “Commission”) on November 1, 2019 and respectfully requests that the Commission consent thereto. The Registrant refiled the Post-Effective Amendment with the correct EDGAR submission type “POS AM” on November 5, 2019.
Because the Post-Effective Amendment was not declared effective by the Commission, no offers or sales were made pursuant to the Post-Effective Amendment.
Thank you for your assistance in this request. Should you have any questions regarding this letter or require any additional information, please do not hesitate to contact Michael M. Philipp or Philip K.W. Smith of Morgan, Lewis & Bockius LLP, counsel to the Co-Registrants, at (312) 324-1905 or (202) 739-5503, respectively.
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| Invesco DB Multi-Sector Commodity Trust |
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By: | | Invesco Capital Management LLC, |
| | its Managing Owner |
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| By: | | * |
| | Name: Daniel Draper |
| | Title: Chief Executive Officer |
