787 Seventh Avenue
				New York, NY 10019-6099
				Tel: 212 728 8000
				Fax: 212 728 8111

January 30, 2018

VIA EDGAR

Samantha Brutlag

Kathy Churko

Division of Investment Management

Securities and Exchange Commission

100 F Street, NE

Washington, DC 20549

(Securities Act File No. 333-221936)

Dear Mses. Brutlag and Churko:

On behalf of BlackRock Variable Series Funds, Inc. (the “BlackRock Registrant”), this letter responds to comments provided by the staff of the Division of Investment Management (the “Staff”) of the Securities and Exchange Commission (the “Commission”) to the undersigned by telephone on January 8, 2018 regarding the BlackRock Registrant’s Registration Statement on Form N-14 (the “Registration Statement”) relating to (i) the proposed acquisition by the BlackRock S&P 500 Index V.I. Fund, a series of the BlackRock Registrant, of substantially all of the assets and certain stated liabilities of the HIMCO VIT Index Fund, a series of the HIMCO Variable Insurance Trust (the “HIMCO Registrant”), in exchange for Class I and Class III shares of the BlackRock S&P 500 Index V.I. Fund, and (ii) the proposed acquisition by the BlackRock Managed Volatility V.I. Fund (together with the BlackRock S&P 500 Index V.I. Fund, the “Acquiring Funds”), a series of the BlackRock Registrant, of substantially all of the assets and certain stated liabilities of the HIMCO VIT Portfolio Diversifier Fund (together with the HIMCO VIT Index Fund, the “Target Funds”), a series of the HIMCO Registrant, in exchange for Class III shares of the BlackRock Managed Volatility V.I. Fund.

The Staff’s comments are summarized below in italicized text. We have discussed the Staff’s comments with representatives of the BlackRock Registrant. The BlackRock Registrant’s responses to the Staff’s comments are set out immediately under the restated comment. Please note that we have not independently verified information provided by the BlackRock Registrant. A Pre-Effective Amendment to the Registration Statement, which reflects changes made in response to the Staff’s comments, along with changes made to update certain other information in the Registration Statement, will be filed at a later date. Unless otherwise indicated, defined terms used herein have the meanings set forth in the Registration Statement.

NEW YORK    WASHINGTON    HOUSTON    PARIS    LONDON    FRANKFURT     BRUSSELS    MILAN    ROME

in alliance with Dickson Minto W.S., London and Edinburgh

January 30, 2018

Page 2

Disclosure Staff Comments

January 30, 2018

Page 3

January 30, 2018

Page 4

January 30, 2018

Page 5

January 30, 2018

Page 6

*    *    *    *    *    *     *    *    *    *

Please do not hesitate to contact me at (212) 728-8955 if you have comments or if you require additional information regarding the Reorganizations.

Gladys Chang, Esq., BlackRock, Inc.

Elliot J. Gluck, Esq., Willkie Farr & Gallagher, LLP

January 30, 2018

Page 7

Appendix A

Draft Form of Tax Opinions

[see next page]

		1095 Avenue of the Americas New York, NY 10036-6797 +1 212 698 3500 Main +1 212 698 3599 Fax www.dechert.com

April     , 2018            DRAFT

Board of Directors

BlackRock S&P 500 Index V.I. Fund

BlackRock Variable Series Funds, Inc.

100 Bellevue Parkway

Wilmington, Delaware 19809

Board of Trustees

HIMCO VIT Index Fund

HIMCO Variable Insurance Trust

One Hartford Plaza

Hartford, Connecticut 06155

Dear Ladies and Gentlemen:

You have requested our opinion regarding certain federal income tax consequences to HIMCO VIT Index Fund (the “Acquired Fund”), a separate series of HIMCO Variable Insurance Trust, a Delaware statutory trust (the “Acquired Fund Trust”), and to BlackRock S&P 500 Index V.I. Fund (the “Acquiring Fund”), a separate series of BlackRock Variable Series Funds, Inc., a Maryland corporation (the “Acquiring Fund Company”), and to the holders of shares of beneficial interest in Acquired Fund (the “Acquired Fund Shareholders”), in connection with the transfer of substantially all of the assets, as defined in paragraph 1.2 of the Agreement and Plan of Reorganization (the “Plan”) dated as of             , 201    , executed by Acquired Fund Trust on behalf of Acquired Fund and by Acquiring Fund Company on behalf of Acquiring Fund, of the Acquired Fund (the “Assets”) to Acquiring Fund in exchange solely for voting shares of common stock of Acquiring Fund (the “Acquiring Fund Shares”) and the assumption of Acquired Fund’s stated liabilities as defined in paragraph 1.3 of the Plan (the “Stated

				Page 2

Liabilities”) by Acquiring Fund, followed by the distribution of the Acquiring Fund Shares received by Acquired Fund in complete liquidation and termination of Acquired Fund (the “Reorganization”), all pursuant to the Plan.

For purposes of this opinion, we have examined and relied upon (1) the Plan, (2) the facts and representations contained in the letter dated on or about the date hereof addressed to us from Acquiring Fund Company on behalf of Acquiring Fund, (3) the facts and representations contained in the letter dated on or about the date hereof addressed to us from Acquired Fund Trust on behalf of Acquired Fund, and (4) such other documents and instruments as we have deemed necessary or appropriate for purposes of rendering this opinion.

This opinion is based upon the Internal Revenue Code of 1986, as amended (the “Code”), United States Treasury Regulations, judicial decisions, and administrative rulings and pronouncements of the Internal Revenue Service, all as in effect on the date hereof. This opinion is conditioned upon the Reorganization taking place in the manner described in the Plan.

Based upon the foregoing, it is our opinion that for federal income tax purposes, with respect to Acquired Fund and Acquiring Fund:

- 2 -

Dechert LLP

				Page 3

- 3 -

Dechert LLP

				Page 4

We express no opinion as to the federal income tax consequences of the Reorganization except as expressly set forth above, or as to any transaction except those consummated in accordance with the Plan. Without limiting the foregoing, we express no opinion as to the federal income tax consequences of the Reorganization to Acquired Fund with respect to contracts described in Section 1256(b) of the Code or stock in a passive foreign investment company, as defined in Section 1297(a) of the Code.

Very truly yours,

- 4 -

Dechert LLP

				1095 Avenue of the Americas New York, NY 10036-6797 +1 212 698 3500 Main +1 212 698 3599 Fax www.dechert.com

April     , 2018            DRAFT

Board of Directors

BlackRock Managed Volatility V.I. Fund

BlackRock Variable Series Funds, Inc.

100 Bellevue Parkway

Wilmington, Delaware 19809

Board of Trustees

HIMCO VIT Portfolio Diversifier Fund

HIMCO Variable Insurance Trust

One Hartford Plaza

Hartford, Connecticut 06155

Dear Ladies and Gentlemen:

You have requested our opinion regarding certain federal income tax consequences to HIMCO VIT Portfolio Diversifier Fund (the “Acquired Fund”), a separate series of HIMCO Variable Insurance Trust, a Delaware statutory trust (the “Acquired Fund Trust”), and to BlackRock Managed Volatility V.I. Fund (the “Acquiring Fund”), a separate series of BlackRock Variable Series Funds, Inc., a Maryland corporation (the “Acquiring Fund Company”), and to the holders of shares of beneficial interest in Acquired Fund (the “Acquired Fund Shareholders”), in connection with the transfer of substantially all of the assets, as defined in paragraph 1.2 of the Agreement and Plan of Reorganization (the “Plan”) dated as of             , 201    , executed by Acquired Fund Trust on behalf of Acquired Fund and by Acquiring Fund Company on behalf of Acquiring Fund, of the Acquired Fund (the “Assets”) to Acquiring Fund in exchange solely for voting shares of common stock of Acquiring Fund (the “Acquiring Fund Shares”) and the assumption of Acquired Fund’s stated liabilities as defined in paragraph 1.3 of

				Page 2

the Plan (the “Stated Liabilities”) by Acquiring Fund, followed by the distribution of the Acquiring Fund Shares received by Acquired Fund in complete liquidation and termination of Acquired Fund (the “Reorganization”), all pursuant to the Plan.

For purposes of this opinion, we have examined and relied upon (1) the Plan, (2) the facts and representations contained in the letter dated on or about the date hereof addressed to us from Acquiring Fund Company on behalf of Acquiring Fund, (3) the facts and representations contained in the letter dated on or about the date hereof addressed to us from Acquired Fund Trust on behalf of Acquired Fund, and (4) such other documents and instruments as we have deemed necessary or appropriate for purposes of rendering this opinion.

This opinion is based upon the Internal Revenue Code of 1986, as amended (the “Code”), United States Treasury Regulations, judicial decisions, and administrative rulings and pronouncements of the Internal Revenue Service, all as in effect on the date hereof. This opinion is conditioned upon the Reorganization taking place in the manner described in the Plan.

Based upon the foregoing, it is our opinion that for federal income tax purposes, with respect to Acquired Fund and Acquiring Fund:

- 2 -

Dechert LLP

				Page 3

- 3 -

Dechert LLP

				Page 4

We express no opinion as to the federal income tax consequences of the Reorganization except as expressly set forth above, or as to any transaction except those consummated in accordance with the Plan. Without limiting the foregoing, we express no opinion as to the federal income tax consequences of the Reorganization to Acquired Fund with respect to contracts described in Section 1256(b) of the Code or stock in a passive foreign investment company, as defined in Section 1297(a) of the Code.

Very truly yours,

- 4 -

Dechert LLP

January 30, 2018

Page 16

Appendix B

Draft Legality of Shares Opinion

[see next page]

February     , 2018 DRAFT

BlackRock Variable Series Funds, Inc.

100 Bellevue Parkway

Wilmington, Delaware 19809

Ladies and Gentlemen:

We have acted as special Maryland counsel to BlackRock Variable Series Funds, Inc., a Maryland corporation (the “Corporation”), in connection with that Registration Statement on Form N-14 (File No. 333-221936, together with all amendments filed through the date hereof but excluding the exhibits thereto, the “Registration Statement”) filed with the Securities and Exchange Commission under the Securities Act of 1933, as amended (the “Act”), which relates to the registration of shares (the “Shares”) of common stock, par value $0.10 per share, of the Company to be issued pursuant to (a) an Agreement and Plan of Reorganization among the Corporation, individually and with respect to BlackRock S&P 500 Index V.I. Fund, a series of the Corporation (the “S&P 500 Acquiring Fund”), HIMCO Variable Insurance Trust, a Delaware statutory trust (the “Selling Trust”), individually and with respect to HIMCO VIT Index Fund, a series of the Selling Trust (the “Index Target Fund”), Hartford Investment Management Company (“Hartford Investment Management”), investment manager to the Index Target Fund, and BlackRock Advisors, LLC (“BlackRock Advisors”), investment manager to the S&P 500 Acquiring Fund, and (b) an Agreement and Plan of Reorganization between the Corporation, individually and with respect to BlackRock Managed Volatility V.I. Fund, a series of the Corporation (the “Volatility Acquiring Fund”, together with the S&P Acquiring Fund, the “Acquiring Funds”), the Selling Trust, individually and with respect to HIMCO VIT Portfolio Diversifier Fund, a series of the Selling Trust (the “Portfolio Diversifier Target Fund”, together with the Index Target Fund, the “Target Funds”), Hartford Investor Management, investment manager to the Portfolio Diversifier Target Fund, and BlackRock Advisors, investment manager to the Volatility Acquiring Fund (together, substantially in the form attached as an exhibit to the Registration Statement and assuming that the respective parties listed above enter into such agreements, the “Agreements”). The Agreements provide for (i) the transfer and delivery of substantially all of the assets of the Target Funds to the Acquiring Funds in exchange for the assumption by the Acquiring Funds of certain stated liabilities of the Target Funds and newly issued shares of the Acquiring Funds; (ii) the distribution of such shares of the Acquiring Funds to shareholders of the Target Funds; and (iii) the termination, dissolution and complete liquidation of the Target Funds as series of the Selling Trust.

We have examined the Registration Statement, the Agreements and such corporate records, certificates and documents as we deemed necessary for the purpose of this opinion. We have relied as to certain factual matters on information obtained from public officials and officers of the Corporation. Based on that examination, we advise you that in our opinion the Shares, when issued under the circumstances contemplated in the Registration Statement and the Agreements, will be legally issued, fully paid and non-assessable.

BlackRock Variable Series Funds, Inc.

February     , 2018

Page 2

With respect to our opinion as to the valid issuance of the Shares, we are assuming that at the time the Shares are issued in accordance with the Registration Statement and the Agreements there will be a sufficient number of authorized but unissued shares of common stock of the Corporation for such issuance.

We express no opinion with respect to the laws of, or the effect or applicability of the laws of, any jurisdiction other than, and our opinion expressed herein is limited to, the laws of the State of Maryland. The opinion expressed herein is limited to the matters expressly set forth in this letter and no other opinion should be inferred beyond the matters expressly stated.

We hereby consent to the use of our name under the heading “Legal Matters” in the Joint Proxy Statement/Prospectus forming a part of the Registration Statement and to the filing of this opinion as an exhibit to the Registration Statement. In giving our consent, we do not thereby admit that we are in the category of persons whose consent is required under Section 7 of the Act or the rules and regulations of the Securities and Exchange Commission thereunder.

Very truly yours,

Miles & Stockbridge P.C.