VIA EDGAR AND ELECTRONIC MAIL

April 20, 2009

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

Re:      Variable Annuity Account Seven ("Registrant")
         AIG SunAmerica Life Assurance Company ("Depositor")
         Polaris II A-Class Platinum Series Variable Annuity
         Form N-4
         File Nos. 333-137882 and 811-09003

Dear Mr. Foor:

         Thank you for your telephone conversation on April 7, 2008 during which
you provided comments to Post-Effective Amendment No. 13 and 14 on Form N-4
filed on February 13, 2009 by Registrant and Depositor. We have considered your
comments and provided our responses below.

     1.  Fee Table, page 5

              a.  Comment -- Please revise the footnote 2 to the Fee Table so
                  that the information regarding the withdrawals charge appears
                  as a separate footnote.

                  Response -- The Fee Table has been revised accordingly.

              b.  Comment -- Please consider modifying the font size of the
                  underlying fund fees to be larger than the font size of the
                  footnotes.

                  Response -- The Fee Table has been modified accordingly.


     2.  General Account, page 53

              a.  Comment -- Please consider adding disclosure describing the
                  impact of the financial condition of the Company on the
                  General Account Obligations.

                  Response -- The following disclosure has been added to the
                  General Account discussion in the prospectus:

                  "Obligations that are paid of the Company's general account
                  ("General Account") include the interest rate on available
                  Fixed Accounts and amounts owed under your contract for death
                  and/or living benefits which are in excess of contract value.
                  The General Account assets are invested in accordance with
                  applicable state regulation. These assets are exposed to the
                  typical risks normally



                  associated with a portfolio of fixed income securities, namely
                  interest rate, option, liquidity and credit risk. The Company
                  manages its exposure to these risks by, among other things,
                  closely monitoring and matching the duration and cash flows of
                  its assets and liabilities, monitoring or limiting prepayment
                  and extension risk in its portfolio, maintaining a large
                  percentage of its portfolio in highly liquid securities and
                  engaging in a disciplined process of underwriting, reviewing
                  and monitoring credit risk. With respect to the living
                  benefits available in your contract, we also manage interest
                  and market risk through a hedging strategy in the portfolio
                  and we require that those who elect a living benefit allocate
                  their Purchase Payments in accordance with specified
                  investment parameters.

                  For additional information about the Company's financial
                  strength, you may wish to review the ratings of the Company
                  published by the Nationally Recognized Statistical Ratings
                  Organizations by accessing their websites: A.M Best Company
                  (www.ambest.com), Moody's Investor Service (www.moodys.com),
                  Standard & Poor's (www.standardandpoors.com) and Fitch Ratings
                  (www.fitchratings.com)."

We will file all revisions and all relevant exhibits and financial statements in
a post-effective amendment to the registration statement on or before April 30,
2009. If you have any further questions, please contact me at 310-772-6545.

Very truly yours,

/s/ Manda Ghaferi

Manda Ghaferi
Assistant General Counsel