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

February 23, 2004

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. 333-111049 and 811-05618
    CIK # 0000836346
    Accession # 0000836346-04-000001
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Dear Sir/Madam:

On February 20, 2004 the  above-referenced  N4/A filing was forwarded via Edgar.
The purpose  this filing was to respond to written  comments  received  from Mr.
Sonny Oh with respect to  Registrant's  Initial  Registration  Statement on Form
N-4,  filed on December 10, 2003.  We are hereby  requesting  withdrawal  of the
previously  accepted filing under Form Type AW and we will be  resubmitting  the
filing.

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