JNL SERIES TRUST
                                 1 Corporate Way
                             Lansing, Michigan 48951
                                 (517) 381-5500


August 22, 2007

VIA EDGAR

Securities and Exchange Commission
450 Fifth Street, NW
Judiciary Plaza
Washington, DC  20549

Re:      JNL Series Trust
         File Nos. 33-87244 and 811-8894

Dear Sir/Madam:

On behalf of JNL Series Trust ("Trust"), enclosed herewith for electronic filing
pursuant to Rule 14a-6(a) under the Securities Exchange Act of 1934, as amended,
are the proxy materials: Notice of Special Meeting, Proxy Statement, and Form of
Proxy and Voting  Instruction  Card to be sent to the  shareholders of the Trust
and its contract owners in connection with a special meeting of shareholders.

The proposal for consideration by Shareholders of the Trust are as follows:

1.   JNL/Putnam  Equity  Fund  only.  To  approve  or  disapprove  a  change  in
     sub-adviser  and  a  proposed  amendment  to  the  Investment  Sub-Advisory
     Agreement between Jackson National Asset  Management,  LLC ("JNAM") and PPM
     America,  Inc.  ("PPM"),  under which PPM would serve as sub-adviser to the
     Fund (the "Proposal").

2.   To transact such other  business as may properly come before the Meeting or
     any adjournment thereof.

The  shareholders'  meeting for the Trust is scheduled to be held on October 15,
2007.  The  definitive  proxy  materials  are  scheduled  to be  mailed  to  the
shareholders and their variable  contract owners on or about September 10, 2007.
Please do not hesitate to contact me at the  above-referenced  number to discuss
the preliminary proxy materials.

Sincerely yours,

By: /s/ Susan S. Rhee

Susan S. Rhee

Enclosures

                                JNL SERIES TRUST
                                 1 Corporate Way
                             Lansing, Michigan 48951
                                 (517) 381-5500


August 22, 2007


VIA EDGAR

U.S. Securities and Exchange Commission
Office of Insurance Products
Division of Investment Management
Attn: Ellen Sazzman

Re:  JNL Series Trust
     File Nos: 33-87244 and 811-8894

Dear Commissioners:

I am writing on behalf of the above  referenced  registrant.  We acknowledge and
agree that:  should the  Commission  (or its staff acting  pursuant to delegated
authority) declare the above referenced  registration  statements effective,  it
does not  foreclose  the  Commission  from taking any action with respect to the
filings; the action of the Commission (or its staff acting pursuant to delegated
authority)  declaring  the  filings  effective  does not  relieve  us from  full
responsibility  for the adequacy and accuracy of the disclosures in the filings;
and we may not assert this action as a defense in any  proceeding  initiated  by
the  Commission  or any person under the federal  securities  laws of the United
States.

Please call me at (517) 367-4336 if you have any questions.

Respectfully,

/s/ Susan S. Rhee

Susan S. Rhee
Vice President, Counsel & Secretary
JNL Series Trust