Allstate Life Insurance Company
                           Law & Regulation Department
                          3100 Sanders Road, Suite J5B
                           Northbrook, Illinois 60062

                         Direct Dial Number 847.402.6461
                             Facsimile 847.402.3781
                          E-Mail bteichne@allstate.com


Bruce A. Teichner
Associate Counsel


April 5, 2006



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

Re:   Allstate Life Insurance Company ("Registrant")
      Post-Effective Amendment No. 4 to Form S-3 Registration Statement
      File No. 333-102319; CIK No. 0000352736

Commissioners:

On behalf of the above-named Registrant, we are filing herewith one
electronically formatted copy of Post-Effective Amendment No. 4 ("Amendment") to
the above-referenced registration statement ("Registration Statement") under the
Securities Act.  To facilitate the Commission staff's review of the Amendment,
Registrant has requested that we submit the information below.

                          1. Amendment

The purpose of the Amendment is to generally update the financial and other
information for the Registrant. The Amendment does not amend or delete any part
of the Registration Statement, except as specifically noted therein.

                         2. Timetable for Effectiveness

Ideally, in order to facilitate the printing of new prospectuses, we would
appreciate receiving the Commission staff's comments on the Amendment as soon as
possible but in any event prior to April 20. Please contact me as soon as
possible if it appears that the April 20 date may not be met so we can manage
the expectations of our client.

At the  appropriate  time,  Registrant,  or its  counsel,  will  orally  request
acceleration of the effectiveness of the Registration Statement pursuant to Rule
461 under the Securities Act. Registrant and its principal  underwriter each has
authorized me to state on its behalf that it is aware of its  obligations  under
the Securities Act.

                         3. Registrant's Acknowledgment

In making its request for acceleration of this Registration Statement,
Registrant hereby acknowledges that should the Commission or the staff, acting
pursuant to delegated authority, declare the filing effective, it does not
foreclose the Commission from taking any action with respect to the filing; the
action of the Commission or the staff, acting pursuant to delegated authority,
in declaring the filing effective, does not relieve Registrant from its full
responsibility for the adequacy and accuracy of the disclosure in the filing;
and Registrant 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 direct any question or comment to me at the number above.

Sincerely,


/s/ BRUCE A. TEICHNER
- --------------------------------
Bruce A. Teichner


Enclosure