[LETTERHEAD OF CAHILL GORDON & REINDEL LLP]
(212) 701-3323
September 11, 2009
| Re: | XL Capital Ltd. |
| | Form 10-K for the Year Ended December 2008 |
| | Schedule 14A |
| | Filed on March 9, 2009 |
| | File No. 001-10804 |
| | Comment Letter dated September 1, 2009 |
Dear Mr. Pitko::
As discussed in our telephone conversion earlier today, XL Capital intends to file its response to your letter on or before September 30, 2009. Particularly in light of the intervening holiday and vacation schedules, the Company requests the additional time in order to ensure that the response is carefully reviewed by all relevant people at the Company.
Please call with any questions.
Division of Corporation Finance
United States Securities and Exchange Commission
100 F Street, N.E., Stop 4720
Washington, D.C. 20549
| cc: | Kirstin R. Gould, Executive Vice President, General Counsel and Secretary |
