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

[LOGO] SECURIAN

January 3, 2013

Securities and Exchange Commission
100 F Street, NE
Washington, D.C.  20549-4644

Re:	Minnesota Life Insurance Company
	Minnesota Life Individual Variable Universal Life Account
	File:  333-183590; 811-22093
	Correspondence Filing - January 2, 2013
	Accession Number:  0000766351-13-000001

Dear Commissioners:

In reference to the above-mentioned correspondence filing, due to a
pagination error, we are re-filing the correspondence with the
corrected page numbers.

If there are additional questions or comments, please contact the
undersigned at (651) 665-4593.

Very truly yours,

/s/ Timothy E. Wuestenhagen

Timothy E. Wuestenhagen
Senior Counsel


cc: 	Thomas E. Bisset, Esq.












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

[LOGO] SECURIAN


December 31, 2012

Securities and Exchange Commission
100 F Street, NE
Washington, D.C.  20549-4644

Re:	Minnesota Life Insurance Company
	Minnesota Life Individual Variable Universal Life Account
	File:  333-183590; 811-22093

Dear Commissioners:

On behalf of Minnesota Life Insurance Company (the "Company") and Minnesota
Life Individual Variable Universal Life Account, we are filing this letter as
correspondence to the Form N-6 registration statement referenced above
(the "Registration Statement").  The letter responds to comments received by
the Company from the staff of the Securities and Exchange Commission ("SEC")
in a phone conversation on December 31, 2012.

Below are responses to the SEC staff's comments.  For the SEC staff's
convenience, each of the SEC staff's comments is set forth below, and then
the response follows.

* * * * * * * * *

1.	Transaction Requests (p.25)

Please add a statement that clarifies when transaction requests that occur
after an early close of the NYSE will be honored.

Response:

In response the SEC Staff request, the second and third sentences in the
section titled Transaction Requests is modified to read as follows (underlined
language will be added via a Rule 497 filing).

This means that if we receive your request for a financial transaction prior
to 3:00 p.m. Central time on a Valuation Date, OR PRIOR TO THE END OF A
VALUATION DATE, we will process the request at the Unit Values determined as
of the end of that Valuation Date.  If we receive your request for a financial
transaction at or after 3:00 p.m. Central time, OR AFTER THE END OF A
VALUATION DATE, or on a non-Valuation Date, we will process the request at the
Unit Values determined as of the end of the next Valuation Date.

Additional conforming language will be made in the section titled Variable
Account Transfers (p.32) and in the section title Partial Surrender (p.47).









Securities and Exchange Commission
December 31, 2012
Page 2 of 2


* * * * * * * * *

The Company believes that the changes noted above satisfy all of the SEC
staff's comments and the clarifying language will be made via the Rule 497
filing after the registration statement is ordered effective by the SEC Staff.
If there are additional questions or comments, please contact the undersigned
at (651) 665-4593.

Very truly yours,

/s/ Timothy E. Wuestenhagen

Timothy E. Wuestenhagen
Senior Counsel


cc: 	Thomas E. Bisset, Esq.