[STRADLEY RONON STEVENS & YOUNG, LLP LETTERHEAD]
 
Matthew R. DiClemente
 
MDiClemente@stradley.com
 
215.564.8173
 
January 31, 2013


Via EDGAR
 
Janet M. Grossnickle
Jaime L. Eichen
U.S. Securities and Exchange Commission
100 F Street, NE
Washington, D.C.  20549-0505

 
Re:
AIM Sector Funds (Invesco Sector Funds) (the “Applicant”)
File No.:  812-14115                                                                                 
 
Ladies and Gentlemen:
 
We respectfully request that the application (the “Application”) requesting authorization from the U.S. Securities and Exchange Commission (the “Commission”), pursuant to section 6(c) of the 1940 Act, exempting the Invesco Utilities Fund, a series of the Applicant, from the provisions of Section 19(b) of the 1940 Act and Rule 19b-1(e) thereunder, be withdrawn and that the Commission takes no further action.  The Application was filed with the Securities and Exchange Commission on January 24, 2013 (Accession No. 0001137439-13-000013).  This request is being made as a result of conversations with the Commission staff.
 
Please direct any questions relating to this filing to me at the above-referenced telephone number.
 
Very truly yours,

/s/ Matthew R. DiClemente                                                                                   
Matthew R. DiClemente