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                                                           July 9, 2024

Brian Hartigan
Chief Executive Officer
Invesco CurrencyShares Australian Dollar Trust
3500 Lacey Road, Suite 700
Downers Grove, Illinois 60515

       Re: Invesco CurrencyShares Australian Dollar Trust
           Registration Statement on Form S-3
           Filed July 1, 2024
           File No. 333-280633
Dear Brian Hartigan:

     We have conducted a limited review of your registration statement and have
the following
comment.

       Please respond to this letter by amending your registration statement
and providing the
requested information. If you do not believe a comment applies to your facts
and circumstances
or do not believe an amendment is appropriate, please tell us why in your
response.

       After reviewing any amendment to your registration statement and the
information you
provide in response to this letter, we may have additional comments.

Registration Statement on Form S-3
General

1.     It appears that the aggregate market value of your common equity held by
non-affiliates
       during the 60 days prior to July 1, 2024 did not exceed the $75 million
threshold that
       General Instruction I.B.1 of Form S-3 specifies. Please provide us with
your analysis
       demonstrating your ability to use Form S-3 pursuant to General
Instruction I.B.1, or if you
       are relying on General Instruction I.B.6 for Form S- 3 eligibility,
include the information
       required pursuant to Instruction 7 to General Instruction I.B.6.
Alternatively, please
       amend your registration statement on an appropriate form.
        We remind you that the company and its management are responsible for
the accuracy and
adequacy of their disclosures, notwithstanding any review, comments, action or
absence of action
by the staff.
 July 9, 2024
Page 2

       Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate
time for us to review any amendment prior to the requested effective date of
the registration
statement.

      Please contact Lulu Cheng at 202-551-3811 or Sandra Hunter Berkheimer at
202-551-
3758 with any other questions.



                                                           Sincerely,

                                                           Division of
Corporation Finance
                                                           Office of Crypto
Assets
cc:   Patrick Daugherty
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