Allianz Life Insurance Company of North America
5701 Golden Hills Drive
Minneapolis, MN  55416-1297
(763) 765-2913

December 8, 2003

VIA EDGAR

Securities and Exchange Commission
Division of Investment Management
Office of Insurance Products
450 Fifth Street, N.W.
Washington, DC 20549


Re: Allianz Life Insurance Company of North America
    Allianz Life Variable Account B
    File Nos. 333-95729 and 811-05618
    CIK # 0000836346
    Accession # 0000836346-03-000082
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Dear Sir/Madam:

On November 21, 2003 the  above-referenced  485a filing was forwarded via Edgar.
The  purpose  of the  485a  amendment  was to  submit a  second  version  of the
prospectus which included disclosure related to additional riders. However, upon
initial review by the Office of Insurance  Products it was  determined  that the
prospectus  should instead be filed as an initial N4 registration.  Therefore we
are requesting  withdrawal of the previously  accepted filing under Form Type AW
and we will be resubmitting the filing as an inital registration under form N4.

Please  contact me with any  questions or comments you may have  concerning  the
enclosed.  I may be reached at the following  address and phone number:  Allianz
Life, 5701 Golden Hills Drive, Mpls, MN 55416. Telephone: (763)765-2913


Sincerely,

Allianz Life Insurance Company of North America

By: /s/ STEWART D. GREGG
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        Stewart D. Gregg