AMERICAN CENTURY INVESTMENTS
4500 MAIN STREET
KANSAS CITY, MISSOURI 64111
December 20, 2005
Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, DC 20549
RE: American Century Variable Portfolios, Inc. (CIK #814680)
Ladies and Gentlemen:
On behalf of the above-referenced Registrant, transmitted herewith for
filing pursuant to Rule 14a-6(a) of Regulation 14(a) under the Securities
Exchange Act of 1934 are preliminary proxy materials relating to a Special
Meeting of the Registrant to be held on March 3, 2006. The Registrant intends to
release to shareholders definitive copies of the proxy statement and form of
proxy on February 1, 2006.
If you have any questions or comments pertaining to this filing, please
direct them to me at (816) 340-3335.
Sincerely,
/s/ Otis H. Cowan
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Otis H. Cowan
Vice President and
Assistant General Counsel
