April 13, 2004

BY EDGAR

Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C. 20549

         Re:      Allstate Life Insurance Company ("Registrant")
                  Form S-3 Registration Statement ("Registration Statement")
                  Post-Effective Amendment No. 1
                  File no. 333-105331
                  CIK No. 0000352736
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     On  behalf  of  the   above-named   Registrant,   filed   herewith  is  one
electronically formatted copy of Post-Effective amendment no. 1 ("Amendment") to
the above-referenced registration statement ("Registration Statement") under the
Securities Act.

     To facilitate the Commission staff's review of the Amendment, we submit the
information below.


                              1. Procedural Matters

     The  purpose  of  the  Amendment  is to  generally  update  the  disclosure
contained in the Registration Statement.  The Amendment does not amend or delete
any part of the Registration Statement, except as specifically noted therein.


                         2. Timetable for Effectiveness

     We would  appreciate  the  Commission  staff's  efforts in  processing  the
Registration  Statement so that the Registration  Statement,  as amended, may be
declared effective by May 1, 2004.

     Accordingly,  Registrant  and the  principal  underwriter  hereby  request,
pursuant  to Rule 461  under  the 1933  Act,  that the  Commission  declare  the
enclosed Post-Effective  Amendment to the Registration Statement effective on or
before May 1, 2004, or as soon as practicable. To our knowledge, no distribution
of copies of the  Post-Effective  Amendment or the  prospectus  has been made to
prospective investors. Distributions thereof have been made only for purposes of
internal  use by  Registrant  and for  regulatory  filings.  Registrant  and the
principal  underwriter  represent that they are aware of their obligations under
the Act and that their  request is consistent  with the public  interest and the
protection of investors.

                            -----------------------

     Please  direct any  question or comment to me at the number set forth above
or to Chip Lunde, Esq. (202-295-4016) at Foley & Lardner.




                                            Very truly yours,


                                            /s/ Charles M. Smith, Jr.
                                            Charles M. Smith, Jr., Esq.
                                            Assistant Counsel


cc:      Alison White, Esq.
         Securities and Exchange Commission