AXA Equitable Life Insurance Company
1290 Avenue of the Americas
New York, NY 10104
Sun-Jin Moon
Vice President
and Counsel
(212) 314-2120
Fax: (212) 707-1791
LAW DEPARTMENT
June 17, 2010
Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Re: AXA Equitable Life Insurance Company (the "Company");
Registration Statement on Form N-6, Reg. No. 333-103199
(the "Registration Statement");
Post-Effective Amendment No. 25 to the Registration Statement,
filed June 17, 2010 (the "Amendment").
Ladies and Gentlemen:
The Company hereby acknowledges that:
o The Company is responsible for the adequacy and accuracy of the
disclosure in the Amendment and the Registration Statement;
o Comments by the staff of the Securities and Exchange Commission (the
"Commission") or changes to disclosure in response to staff comments
on the Amendment do not foreclose the Commission from taking any
action with respect to the Amendment or the Registration Statement;
o The Company may not assert staff comments as a defense in any
proceeding initiated by the Commission or any person under the federal
securities laws of the United States.
Please contact the undersigned at (212) 314-2120 if you have any questions or
comments.
Respectfully submitted,
AXA Equitable Life Insurance Company
By: /s/ Sun-Jin Moon
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Sun-Jin Moon