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                                                                    THE HARTFORD

September 11, 2006

VIA EDGAR

Mr. Michael L. Kosoff
Staff Attorney -- Office of Insurance Products
Division of Investment Management
Securities and Exchange Commission
100 F Street NE
Washington, D.C. 20549-4644

Re: Post-Effective Amendment No. 18 to the Registration Statement on Form N-4
    for Hartford Life Insurance Company Separate Account Twelve (File No.
    33-59541)

Dear Mr. Kosoff:

Enclosed is one copy of Post-Effective Amendment No. 18 to the above-referenced
registration statement on Form N-4 (the "Registration Statement") that was filed
with the Securities and Exchange Commission on September 11, 2006 by Hartford
Life Insurance Company ("Hartford"). In addition to the unmarked copy, Hartford
has included one copy of the Registration Statement's prospectus, redlined to
show the changes from the prospectus in the Post-Effective Registration
Statement filed by Hartford on July 14, 2006. Page numbers below refer to the
redlined copy of the Registration Statement prospectus. Capitalized terms used
and not otherwise defined are consistent with the defined terms set forth in the
applicable Registration Statement's prospectus.

The purpose of Post-Effective Amendment No. 18 is to respond to Staff comments
provided to Hartford by phone on August 29, 2006 with respect to Post-Effective
Amendment No. 17. Hartford's responses incorporating the Staff's comments are
discussed below.

       1.   The example table disclosure has been adjusted to reflect a
            Participant Account value of $10,000.

       2.   The fee table on page 5 of the prospectus represents the current
            maximum total fund operating expenses.

Hartford believes that it has been fully responsive to the Staff's comments,
that the responses do not raise additional issues for the Staff's consideration
and that, other than the changes discussed above, no material changes have been
made in the Post-Effective Amendment.

We hereby acknowledge that the Staff of the Commission has not passed upon the
accuracy or adequacy of the prospectus and related statement of additional
information for the above referenced registration statement filed on Form N-4 on
September 11, 2006.

We acknowledge that the review of the filing by the Staff of the Commission does
not relieve the registrant of its full responsibility for the adequacy and
accuracy of the disclosure of this filing nor does it foreclose the Commission
from taking any action with respect to the filing.

Further, we acknowledge that the registrant may not assert as a defense in any
proceeding initiated by the Commission or any person under federal securities
law that the Staff of the Commission reviewed the filing and provided comments
to the registrant or that the filing became automatically effective thereafter.

We appreciate your attention to this filing. If you have any comments or
questions, please call me at (860) 843-8336, or Chris Grinnell at (860)
843-5445.

Very truly yours,

/s/ Shane Daly

Shane Daly
Counsel