[GRAPHIC OMITTED] ASPEN INSURANCE HOLDINGS LIMITED Securities and Exchange Commission Division of Corporation Finance 450 Fifth Street, N.W. Washington, D.C. 20549 January 13, 2005 RE: ASPEN INSURANCE HOLDINGS LIMITED REGISTRATION STATEMENT ON FORM F-4 Ladies and Gentlemen: Aspen Insurance Holdings Limited (the "Issuer") has filed the above referenced Registration Statement on Form F-4 (the "Registration Statement") with the Securities and Exchange Commission on January 13, 2005. The Registration Statement will be used in connection with the exchange of up to $250,000,000 of the Issuer's 6.00% Senior Notes Due 2014, issued on August 16, 2004 (the "Outstanding Notes") which were issued in a transaction which was exempt from registration under the Securities Act of 1933, as amended (the "Securities Act") for the Issuer's 6.00% Senior Notes Due 2014 which are intended to be registered under the Securities Act. Enclosed with this transmittal letter, please find a supplemental letter which includes certain representations of the Issuer relating to the above described exchange. Very truly yours, Aspen Insurance Holdings Limited By: /s/ Julian Cusack ----------------- Julian Cusack Chief Financial Officer Aspen Insurance Holdings Limited Victoria Hall 11 Victoria Street Hamilton HM 11, Bermuda Tel: 441-295-8201 * Fax: 441-295-1829 www.aspen.bm
