  We extend an earlier proposal for a gauge invariant description of off-shell
open strings (at tree level), using loop variables, to off-shell closed strings
(at tree level). The basic idea is to describe the closed string amplitudes as
a product of two open string amplitudes (using the technique of kawai, Lewellen
and Tye). The loop variable techniques that were used earlier for open strings
can be applied here {\it mutatis mutandis}. It is a proposal for a theory whose
on-shell amplitudes coincide with those of the closed bosonic string in 26
dimensions. It is also gauge invariant off-shell. As was the case with the open
string, the interacting closed string looks like a free closed string thickened
to a band.
