February 9, 2009
VIA EDGARLINK
Securities and Exchange Commission
450 Fifth Street, NW
Washington, DC 20549
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| RE: |
| Protective Life Insurance Company |
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| Pre-Effective Amendment for |
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| Registration Statement on Form S-1 for |
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|
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| Modified Guaranteed Annuity Contracts |
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| File No. 333-156285 |
Commissioners:
Pursuant to Rule 461 under the Securities Act of 1933, the Registrant referenced above hereby requests that the effective date of the above-captioned registration statement filed on Form S-1 be accelerated to February 13, 2009 or as soon thereafter as is reasonably practicable.
| Protective Life Insurance Company | |
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| By: | /s/ John D. Johns |
| Name: | John D. Johns |
| Title: | Chairman of the Board, Chief Executive |
INVESTMENT DISTRIBUTORS, INC.
2801 Highway 280 South · Birmingham, AL · 35223 · (205)268-1000
February 9, 2009
VIA EDGARLINK
Securities and Exchange Commission
450 Fifth Street, NW
Washington, DC 20549
|
| RE: |
| Protective Life Insurance Company |
|
|
|
| Pre-Effective Amendment No. 1 for |
|
|
|
| Registration Statement on Form S-1 for |
|
|
|
| Modified Guaranteed Annuity Contracts |
|
|
|
| File No. 333-156285 |
Commissioners:
Pursuant to Rule 461 under the Securities Act of 1933, Investment Distributors, Inc., as principal underwriter, hereby joins in a request by the above referenced Registrant that the effective date of the above-captioned registration statement filed on Form S-1 be accelerated to February 13, 2009 or as soon thereafter as is reasonably practicable.
| Investment Distributors, Inc. | |
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| |
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| By: | /s/ Edwin V. Caldwell II |
| Name: | Edwin V. Caldwell, II |
| Title: | President and Secretary |
