Erik Nelson, Sr. Securities Counsel
Allianz Investment Management LLC
5701 Golden Hills Drive | Minneapolis Minnesota | 55416-1297
Telephone:  763-765-7453
Fax 763-765-6355

February 12, 2010

Sally Samuel, Senior Counsel
Securities and Exchange Commission
Division of Investment Management
Office of Insurance Products
100 F Street NE
Washington, DC  20549

     RE:   Preliminary Proxy Materials for the Allianz Variable Insurance
           Products Trust
           (SEC File Nos. 333-83423 and 811-09491)

Dear Ms. Samuel:

On February 11, 2010, you provided telephonic comments regarding the
above-referenced proxy materials, which we submitted February 1, 2010. The proxy
materials relate to a special meeting of shareholders for three funds of the
Allianz Variable Insurance Products Trust.

This letter responds to your comments with respect to the proxy materials for
the AZL S&P 500 Index Fund and the AZL Small Cap Stock Index Fund, which seek
approval of the Funds' subadviser and manager of managers order. Each comment is
summarized below, followed by our response.

You did not provide comments with respect to the separate proxy materials for
the AZL Schroder Emerging Markets Fund, which seeks approval of the Fund's
manager of managers order. We will review and make corresponding changes to
those proxy materials to the extent that your comments are applicable.

If I have misstated any of your comments, or if you have any additional
comments, please let me know.

COMMENT: You requested that we revise references to approval of the subadviser
to make clear that approval would be retroactive to October 26, 2009.

RESPONSE: We will revise references to approval of the subadviser on the cover
page, on the notice of meeting and on the first page of the proxy statement to
read "To approve BlackRock Investment Management, LLC as the subadviser for each
of the Funds, effective October 26, 2009."

COMMENT:  You requested that we clearly note that each proposal is independent.

RESPONSE: We will add the following to the cover page, to the notice of meeting
and to the first page of the proxy statement: "Each proposal is independent; a
proposal could be approved even if other proposals are not approved."

COMMENT:  You noted that the proxy materials do not identify the Funds'
principal underwriter.

RESPONSE:  We will note that Allianz Life Financial Services, LLC is the Funds'
distributor and principal underwriter.

COMMENT: You requested that we revise the discussion in the second paragraph
under "Allianz Investment Management LLC (the "Manager")" to be clear that the
investment management agreement with the Manager and the subadvisory agreement
with Dreyfus were approved by the initial sole shareholder, and therefore not
require to be approved by a vote of shareholders, and that shareholder approval
is now being sought for the subadvisory agreement with BlackRock due to
representations made in connection with the Substitution Order.

RESPONSE:  We will revise this discussion as requested.

COMMENT: You requested that we review Item 22(c)(1)(vi) and consider adding
additional detail regarding the reasons for the termination of Dreyfus.

RESPONSE: We will add additional detail relating to the Manager's recommendation
to replace Dreyfus with BlackRock at the 3rd and 4th paragraphs under "Board
Consideration of the BlackRock Agreement."

COMMENT: You requested that we add a tabular presentation of the information
required by Item 22(c)(9).

RESPONSE: We will add a tabular presentation of the information required by Item
22(c)(9) under "Advisory and Subadvisory Fees."

COMMENT: You requested that we provide additional explanation of why the Board
concluded it was appropriate for the Manager to retain the benefit of
BlackRock's lower subadvisory fees.

RESPONSE: We will provide additional explanation under "The costs of services to
be provided and profits to be realized by BlackRock from its relationship with
the Fund."

The Registrant acknowledges that the Registrant is responsible for the adequacy
and accuracy of the disclosure in the filing. Staff comments on the filing and
changes to the filing following staff comments do not foreclose the Commission
from taking an action with respect to the filing and does not relieve the
Registrant from its full responsibility for the adequacy and accuracy of the
disclosure in the filing. The Registrant understands that it cannot raise the
fact that the staff reviewed the filing as a defense in any proceeding initiated
by the Commission or any person under the federal securities laws of the United
States.

Sincerely,

/s/ Erik Nelson