Securian Financial Group, Inc.
400 Robert Street North
St. Paul, MN 55101-2098
www.securian.com
651.665.3500

                                                                 [LOGO]
                                                                SECURIAN



April 24, 2008

Mr. Craig Ruckman
Office of Insurance Products
Securities and Exchange Commission
100 F Street, NE
Washington, D.C. 20549-4644

Re:  File Number 811-8830 - - Response to Comments of the Securities and
     Exchange Commission Staff

                                                Via Facsimile to 202-772-9285

Dear Mr. Ruckman:

I am responding to the Staff?s comments on file number 811-8830 for the
Minnesota Life Variable Universal Life Account.  In addition to your comments,
this memorandum addresses the Staff?s comments on file number 811-21859 (each
hereinafter referred to as a ?File? or collectively the ?Files?) for our
Securian Life Variable Universal Life Account.  We desire to keep these two
contracts as consistent as possible.  Each response indicates the textual
change(s) made and, where applicable, I have attached the revised pages noting
any required revisions.

   .  The Staff requested that we modify the ?Periodic Charges Other Than
      Fund Operating Expenses? table to include a maximum and minimum charge
      row for contracts issued before January 1, 2009 and a maximum and
      minimum row for contracts issued on and after January 1, 2009.

      Response: We have revised the ?Periodic Charges Other Than Fund
      Operating Expenses? table to include the rows requested by the Staff
      (please see the attached revision marked page 8).

   .  The Staff requested that we include a footnote on the ?Periodic Charges
      Other Than Fund Operating Expenses? table to indicate that the ?Charge
      for a 45 year old Non-smoking Certificateholder? is applicable to
      contracts issued both before and after January 1, 2009.

      Response:  We have revised the ?Periodic Charges Other Than Fund
      Operating Expenses? table to include the footnote requested by the
      Staff (please see the attached revision marked page 8).



Securian Financial Group provides financial security for individuals and
businesses through its subsidiaries including Minnesota Life Insurance
Company, Advantus Capital Management, Securian Financial Services and Securian
Trust Company.

Mr. Ruckman
SEC Response File 811-8830
Page 2

Thank you very much for your assistance on this matter.  I look forward to
hearing from you shortly.

Sincerely,

/s/Ted Schmelzle

Ted Schmelzle
Counsel
651-665-3930
theodore.schmelzle@securian.com


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