| November 10, 2009 |
| Office of Filings, Information & Consumer Services Securities and Exchange Commission 100 F Street, NE Washington, D.C. 20549 |
| RE: | Investment Company Act | ||
| Fund Name | of 1940 File No. | ||
| Eaton Vance Insured California Municipal Bond Fund | 811-21147 | ||
| Eaton Vance Insured California Municipal Bond Fund II | 811-21217 | ||
| Eaton Vance Insured Massachusetts Municipal Bond Fund | 811-21225 | ||
| Eaton Vance Insured Michigan Municipal Bond Fund | 811-21224 | ||
| Eaton Vance Insured Municipal Bond Fund | 811-21142 | ||
| Eaton Vance Insured Municipal Bond Fund II | 811-21219 | ||
| Eaton Vance Insured New Jersey Municipal Bond Fund | 811-21229 | ||
| Eaton Vance Insured New York Municipal Bond Fund | 811-21148 | ||
| Eaton Vance Insured New York Municipal Bond Fund II | 811-21218 | ||
| Eaton Vance Insured Ohio Municipal Bond Fund | 811-21226 | ||
| Eaton Vance Insured Pennsylvania Municipal Bond Fund | 811-21227 | ||
| (each a “Registrant”) |
Ladies and Gentlemen:
On behalf of the above-referenced Registrants, transmitted herewith, pursuant to Rule 14a-6 under the Securities Exchange Act of 1934 and Regulation S-T, are preliminary copies of the Shareholder Letter, Notice of Meeting, Proxy Statement and forms of Proxy (“proxy materials”) for each Registrant regarding a joint Special Meeting of Shareholders to be held on Friday, January 29, 2010.
The shareholders are being asked to consider the following proposal:
| 1. | To consider and act upon a proposal to modify each Fund’s investment policy to eliminate the requirement that the Fund invest at least 80 percent of its net assets in municipal obligations that are insured as to the payment of principal and interest. |
The record date for shareholders entitled to receive the proxy materials is November 18, 2009, and the definitive proxy materials will be mailed to such shareholders on or about November 30, 2009.
If you have any questions or comments concerning the foregoing or the enclosed, kindly call me at (617) 672-8064.
| Very truly yours, /s/ Velvet R. Regan Velvet R. Regan, Esq. Vice President |
