XXXX, XXXXX, X'XXXXX, XXXXXXXX & XXXXXXX
A Law Partnership
Including Professional Corporations
29th Floor
0000 Xxxxxxxxxxx Xxxxxx
Xxxxxx, Xxxxxxxx 00000-5529
Telephone (000) 000-0000
Telecopier (000) 000-0000
May 18, 1994
INVESCO Specialty Funds, Inc.
0000 X. Xxxxx Xxxxxx, Xxxxx 000
Xxxxxx, Xxxxxxxx 00000
Gentlemen:
This is in response to your request for our opinion as to the legality of
the registration of an indefinite number of shares of capital stock ($0.01) par
value per share) of INVESCO Specialty Funds, Inc., being registered with the
Securities and Exchange Commission under the Investment Company Act of 1940 and
the Securities Act of 1933, as amended (Form N-1A). This share registration is
being requested pursuant to the provisions of Rule 24f-2 under Section 24(f) of
the Investment Company Act of 1940.
We have examined the articles of incorporation of INVESCO Specialty Funds,
Inc. as filed for record with the State Department of Assessments and Taxation
of the State of Maryland on April 12, 1994; the bylaws; the minute book setting
forth, among other things, the actions taken by the board of directors
authorizing the issuance and sale of the corporation's capital stock and related
acts and procedures; the registration statement including all exhibits thereto;
and have made such other examinations as deemed necessary in the premises.
Based upon our examination, we are of the opinion that INVESCO Specialty
Funds, Inc. is a corporation duly organized and existing under and by virtue of
the laws of the State of Maryland, with full power to issue its shares of
capital stock. Said shares, up to the maximum amount hereinafter indicated, when
issued and sold in the manner and on the terms set forth in the registration
statement, will be legally and validly issued, fully paid and non-assessable
shares of the corporation of the par value of $0.01 per share. The maximum
number of shares which has been authorized by the Corporation, and thus the
maximum number which may be legally and validly be issued, is five hundred
million shares of such capital stock.
We hereby consent to the use of this opinion in the registration
statement and further consent to the reference to our name therein.
Very truly yours,
XXXX, XXXXX, X'XXXXX,
XXXXXXXX & XXXXXXX
By: Xxxxxx X. X'Xxxxx, P.C.
By: /s/ Xxxxxx X. X'Xxxxx
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Xxxxxx X. X'Xxxxx, President
