Pruco Life Insurance Company
Pruco Life Insurance Company of New Jersey

Strategic Partners Annuity One
Strategic Partners Plus
Strategic Partners Annuity One 3
Strategic Partners Plus 3

Strategic Partners FlexElite

Strategic Partners Advisor

Strategic Partners Select

Supplement, dated November 20, 2006
To
Prospectuses, dated May 1, 2006

This supplement makes the following changes:

. adds the Highest Daily Lifetime Five Benefit to Strategic Partners
Annuity One 3, Strategic Partners Plus 3 and Strategic Partners FlexElite
of Pruco Life Insurance Company ("Pruco Life") (but not Pruco Life
Insurance Company of New Jersey); and
. for each of the above-referenced prospectuses, reflects certain changes
to the underlying mutual funds; and
. for each of the above-referenced prospectuses, reflects a change to the
description of the maximum annuity date.

TABLE OF CONTENTS

As a new entry within the line item entitled "Section 5: What Is The Lifetime
Five Income Benefit?", we add a line item for Highest Daily Lifetime Five.

As a new entry at the end of the Table of Contents, we add a reference to
Appendix C, entitled "Asset Transfer Formula Under Highest Daily Lifetime Five
Benefit."

GLOSSARY

. We add a definition for "Benefit Fixed Rate Account", that reads as
follows: "An investment option offered as part of this contract that is
used only if you have elected the optional Highest Daily Lifetime Five
Benefit. Amounts allocated to the Benefit Fixed Rate Account earn a fixed
rate of interest, and are held within our general account. You may not
allocate purchase payments to the Benefit Fixed Rate Account. Rather,
contract value is transferred to the Benefit Fixed Rate Account only
under the asset transfer feature of the Highest Daily Lifetime Five
Benefit."
. We revise the first sentence of the definition of "Annual Income Amount"
to state: "Under the terms of the Lifetime Five Income Benefit and the
Highest Daily Lifetime Five Benefit, an amount that you can withdraw each
year as long as the annuitant lives."
. We revise the first sentence of the definition of "Excess Income/Excess
Withdrawal" to state: "Under the Lifetime Five Income Benefit, Spousal
Lifetime Five Income Benefit, and Highest Daily Lifetime Five Benefit,
Excess Income refers to cumulative withdrawals that exceed the Annual
Income Amount."
. We add a definition for "Highest Daily Lifetime Five Benefit" that reads
as follows: "An optional feature available for an additional charge that
guarantees your ability to withdraw amounts equal to a percentage of a
principal value called the Protected Withdrawal Value. Subject to our
rules regarding the timing and amount of withdrawals, we guarantee these
withdrawal amounts, regardless of the impact of market performance on
your contract value."
. We revise the definition of "Protected Withdrawal Value" to read as
follows: "Under the Lifetime Five Income Benefit, Spousal Lifetime Five
Income Benefit, and Highest Daily Lifetime Five Benefit, an amount that
we guarantee regardless of the investment performance of your contract
value. As discussed in Section 5, Protected Withdrawal Value is
determined one way with respect to the Lifetime Five Income Benefit and
the Spousal Lifetime Five Income Benefit, and another way for the Highest
Daily Lifetime Five Benefit."

SUMMARY

. We revise the last paragraph of the Section 3 portion of the Summary to
read as follows: "The Lifetime Five Income Benefit, Spousal Lifetime Five
Income Benefit, and Highest Daily Lifetime Five Benefit (discussed in
Section 5) and the Income Appreciator Benefit (discussed in Section 6)
each may provide an additional amount upon which your annuity payments
are based."
. We add the following as the last paragraph of the Section 5 portion of
the Summary, to read as follows: "Finally, we offer a benefit called the
Highest Daily Lifetime Five Benefit. The Highest Daily Lifetime Five
Benefit, like Lifetime Five, offers a Life Income Benefit based on a
single designated life, but differs in that (a) the Protected Withdrawal
Value is determined based on the highest daily contract value and (b) we
require you to participate in an asset transfer program, under which your
contract value may be transferred periodically between the variable
investment options and the Benefit Fixed Rate Account. We operate the
asset transfer program under a formula, which is described in the portion
of Section 5 concerning the Highest Daily Lifetime Five Benefit. In
addition, in Appendix C, we set out the formula itself. As discussed in
Section 5, when you elect Highest Daily Lifetime Five, the asset transfer
formula is made a part of your annuity contract, and thus may not be
altered thereafter. However, we do reserve the right to amend the formula
for newly-issued annuity contracts that are issued in the future."

. We add the following as the last line item in the bullet within the
Section 8 portion of the Summary concerning insurance and administrative
costs:

"- 0.60% if you choose the Highest Daily Lifetime Five Benefit. This charge
is in addition to the charge for the applicable death benefit."

SUMMARY OF CONTRACT EXPENSES

. With respect to the Strategic Partners Annuity One 3 and Strategic
Partners Plus 3 prospectuses of Pruco Life, in the table entitled
Periodic Account Expenses, Insurance and Administrative Expenses with the
Indicated Benefits, we revise the line items pertaining to the death
benefit options, Lifetime Five, and Spousal Lifetime Five to read as
follows, and add a line item for Highest Daily Lifetime Five. In
addition, we add a footnote (which appears immediately after "Insurance
And Administrative Expenses With The Indicated Benefits"):

Contract Contract
With Without
Credit Credit
-------- --------

Lifetime Five Income Benefit 0.60% 0.60%
Spousal Lifetime Five Income Benefit 0.75% 0.75%
Highest Daily Lifetime Five Income Benefit 0.60% 0.60%
Base Death Benefit 1.50% 1.40%
Guaranteed Minimum Death Benefit Option - Roll-Up or Step-Up 1.75% 1.65%
Guaranteed Minimum Death Benefit Option - Greater of Roll-Up or Step-Up 1.85% 1.75%
Highest Daily Value Death Benefit 2.00% 1.90%

* The charge for the Lifetime Five Income Benefit (and, if available under your
contract, Spousal Lifetime Five and Highest Daily Lifetime Five) is imposed
based on the value of assets in the variable investment options only. As
discussed later in this prospectus, we reserve the right to increase these
charges upon any step-up of the benefit.

. With respect to the Strategic Partners FlexElite prospectus of Pruco
Life, in the table entitled Periodic Account Expenses, Insurance and
Administrative Expenses with the Indicated Benefits, we revise the line
items pertaining to the death benefit options, Lifetime Five, and Spousal
Lifetime Five to read as follows, and add a line item for Highest Daily
Lifetime Five. In addition, we add a footnote (which appears immediately
after "Insurance And Administrative Expenses With The Indicated
Benefits"):

Lifetime Five Income Benefit 0.60%
Spousal Lifetime Five Income Benefit 0.75%
Highest Daily Lifetime Five Income Benefit 0.60%
Base Death Benefit 1.65% (1.70% for contracts sold prior to
May 1, 2003, or upon subsequent state approval,
and if you are aged 76 or older)
Guaranteed Minimum Death Benefit Option - Roll-Up or Step-Up 1.90%
Guaranteed Minimum Death Benefit Option - Greater of Roll-Up
or Step-Up 2.00%
Highest Daily Value Death Benefit 2.15%

In Section 2 of each prospectus, we make the following change to the chart
setting forth a brief description of each variable investment option, to
reflect a subadviser name change:

. SP Small Cap Value Portfolio, AST Small Cap Value Portfolio, and
Prudential Series Fund Equity Portfolio. Salomon Brothers Asset
Management will change its name to ClearBridge Advisers LLC, effective in
December 2006.

In section 2 of each prospectus, we revise the investment objectives/policies
section, and portfolio adviser/sub-adviser section for two Portfolios to read
as follows. These new descriptions reflect the addition of sub-advisers as well
as revisions to non-fundamental investment policies:

. SP LSV International Value Portfolio:

PORTFOLIO
STYLE/ ADVISER/
TYPE INVESTMENT OBJECTIVES/POLICIES SUB-ADVISER
------ ----------------------------------------- -----------

International Equity SP International Value Portfolio LSV Asset
(formerly SP LSV International Value Management,
Portfolio): seeks capital growth. The Thornburg
Portfolio normally invests at least 80% Investment
of the Portfolio's investable assets (net Management,
assets plus borrowings made for Inc.
investment purposes) in the equity
securities of companies in developed
countries outside the United States that
are represented in the MSCI EAFE
Index.

. SP William Blair International Growth Portfolio

PORTFOLIO
STYLE/ ADVISER/
TYPE INVESTMENT OBJECTIVES/POLICIES SUB-ADVISER
------ -------------------------------------------------------------- -----------

International Equity SP International Growth Portfolio (formerly, SP William Marsico
Blair International Growth Portfolio): seeks long-term Capital
capital appreciation. The Portfolio invests primarily in Management
equity-related securities of foreign issuers. The Portfolio LLC,
invests primarily in the common stock of large and William
medium-sized foreign companies, although it may also Blair &
invest in companies of all sizes. Under normal Company,
circumstances, the Portfolio invests at least 65% of its total LLC
assets in common stock of foreign companies operating or
based in at least five different countries, which may include
countries with emerging markets. The Portfolio looks
primarily for stocks of companies whose earnings are
growing at a faster rate than other companies or which
offer attractive growth potential.

SECTION 5: WHAT IS THE LIFETIME FIVE INCOME BENEFIT?

We add the following new section to the end of the above-referenced section of
each prospectus for Pruco Life's Strategic Partners Annuity One 3, Strategic
Partners Plus 3, and Strategic Partners FlexElite:

HIGHEST DAILY LIFETIME FIVE BENEFIT (HIGHEST DAILY LIFETIME FIVE)

The Highest Daily Lifetime Five Benefit described below is only being offered
in those jurisdictions where we have received regulatory approval, and will be
offered subsequently in other jurisdictions when we receive regulatory approval
in those jurisdictions. Certain terms and conditions may differ among
jurisdictions once approved. Highest Daily Lifetime Five is offered as an
alternative to Lifetime Five and Spousal Lifetime Five. Currently, if you elect
Highest Daily Lifetime Five and subsequently terminate the benefit, you will
not be able to re-elect Highest Daily Lifetime Five, and will have a waiting
period until you can elect Spousal Lifetime Five or Lifetime Five.
Specifically, you will be permitted to elect Lifetime Five or Spousal Lifetime
Five only on an anniversary of the contract date that is at least 90 calendar
days from the date that Highest Daily Lifetime Five was terminated. We reserve
the right to further limit the election frequency in the future. The income
benefit under Highest Daily Lifetime Five currently is based on a single
"designated life" who is at least 55 years old on the date that the benefit is
acquired. The Highest Daily Lifetime Five Benefit is not available if you elect
any other optional living benefit, although you may elect any optional death
benefit (other than the Highest Daily Value Death Benefit). As long as your
Highest Daily Lifetime Five Benefit is in effect, you must allocate your
contract value in accordance with the then-permitted and available investment
option(s) with this program.

We offer a benefit that guarantees until the death of the single designated
life the ability to withdraw an annual amount (the "Highest Daily Life Income
Benefit") equal to a percentage of an initial principal value (the "Protected
Withdrawal Value") regardless of the impact of market performance on the
contract value, subject to our program rules regarding the timing and amount of
withdrawals. The benefit may be appropriate if you intend to make periodic
withdrawals from your contract, and wish to ensure that market performance will
not affect your ability to receive annual payments. You are not required to
make withdrawals as part of the program -- the guarantees are not lost if you
withdraw less than the maximum allowable amount each year under the rules of
the benefit. We discuss Highest Daily Lifetime Five in greater detail
immediately below. In addition, please see the Glossary section of this
prospectus for definitions of some of the key terms used with this benefit. As
discussed below, we require that you participate in our asset transfer program
in order to participate in Highest Daily Lifetime Five, and in the Appendices
to this prospectus, we set forth the formula under which we make those asset
transfers.

As discussed below, a key component of Highest Daily Lifetime Five is the
Protected Withdrawal Value, which is an amount that is distinct from contract
value. Protected Withdrawal Value is used to determine the Highest Daily Annual
Income Amount -- which is amount that you can take out annually as a withdrawal
for your entire life. Because each of the Protected Withdrawal Value and
Highest Daily Annual Income Amount is determined in a way that is not solely
related to contract value, it is possible for the contract value to fall to
zero, even though the Highest Daily Annual Income Amount remains. You are
guaranteed to be able to withdraw the Highest Daily Annual Income Amount for
the rest of your life, provided that you have not made "excess withdrawals."
Excess withdrawals, as discussed below, will reduce your Highest Daily Annual
Income Amount. Thus, you could experience a scenario in which your contract
value was zero, and, due to your excess withdrawals, your Highest Daily Annual
Income Amount also was reduced to zero. In that scenario, no further amount
would be payable under Highest Daily Lifetime Five.

KEY FEATURE -- PROTECTED WITHDRAWAL VALUE

The Protected Withdrawal Value is used to determine the amount of the annual
payments under the Highest Daily Life Income Benefit. The Protected Withdrawal
Value initially is equal to the contract value on the date that you elect
Highest Daily Lifetime Five. On each business day thereafter, until the earlier
of the first withdrawal or ten years after the date of your election of the
benefit, we recalculate the Protected Withdrawal Value. Specifically, on each
such business day (the "Current Business Day"), the Protected Withdrawal Value
is equal to the greater of:

. The Protected Withdrawal Value for the immediately preceding business day
(the "Prior Business Day"), appreciated at the daily equivalent of 5%
annually during the calendar day(s) between the Prior Business Day and
the Current Business Day (i.e., one day for successive business days, but
more than one calendar day for business days that are separated by
weekends and/or holidays), plus the amount of any purchase payment
(including any associated credit) made on the Current Business Day; and

. The contract value.

We cease these daily calculations of the Protected Withdrawal Value when you
make your first withdrawal. However, as discussed below, subsequent purchase
payments (and any associated credits for Strategic Partners Annuity One 3 and
Strategic Partners Plus 3 only) will increase the amount we guarantee to pay
annually under the Highest Daily Life Income Benefit (the "Highest Daily Annual
Income Amount"), while "excess" withdrawals (as described below) may decrease
the Highest Daily Annual Income Amount.

KEY FEATURE - HIGHEST DAILY ANNUAL INCOME AMOUNT UNDER HIGHEST DAILY LIFETIME
FIVE BENEFIT

The initial Highest Daily Annual Income Amount is equal to 5% of the Protected
Withdrawal Value. Under the Highest Daily Lifetime Five benefit, if your
cumulative withdrawals in a contract year are less than or equal to the Highest
Daily Annual Income Amount, they will not reduce your Highest Daily Annual
Income Amount in subsequent contract years, but any such withdrawals will
reduce the Highest Daily Annual Income Amount on a dollar-for-dollar basis in
that contract year. If your cumulative withdrawals are in excess of the Highest
Daily Annual Income Amount ("Excess Income"), your Highest Daily Annual Income
Amount in subsequent years will be reduced (except with regard to required
minimum distributions) by the result of the ratio of the Excess Income to the
contract value immediately prior to such withdrawal (see examples of this
calculation below). Reductions include the actual amount of the withdrawal,
including any CDSC that may apply. A purchase payment that you make will
increase the then-existing Highest Daily Annual Income Amount by an amount

equal to 5% of the purchase payment (including, with respect to Strategic
Partners Annuity One 3 and Strategic Partners Plus 3 only, the amount of any
associated credits).

An automatic step-up feature ("Highest Quarterly Auto Step-Up") is included as
part of this benefit. As detailed in this paragraph, the Highest Quarterly Auto
Step-Up feature can result in a larger Highest Daily Annual Income Amount if
your contract value increases subsequent to your first withdrawal. We begin
examining contract values for purposes of this feature starting with the
contract anniversary immediately after your first withdrawal under the benefit.
Specifically, upon the first such contract anniversary, we identify the
contract value on the business days corresponding to the end of each quarter
that (i) is based on your contract year, rather than a calendar year (ii) is
subsequent to the first withdrawal and (iii) falls within the immediately
preceding contract year. If the end of any such quarter falls on a holiday or a
weekend, we use the next business day. We multiply each of those quarterly
contract values by 5%, adjust each such quarterly value for subsequent
withdrawals and purchase payments, and then select the highest of those values.
If the highest of those values exceeds the existing Highest Daily Annual Income
Amount, we replace the existing amount with the new, higher amount. Otherwise,
we leave the existing Highest Daily Annual Income Amount intact. In later years
(i.e., after the first contract anniversary after the first withdrawal), we
determine whether an automatic step-up should occur on each contract
anniversary, by performing a similar examination of the contract values on the
end of the four immediately preceding quarters. If, on the date that we
implement a Highest Quarterly Auto Step-Up to your Highest Daily Annual Income
Amount, the charge for Highest Daily Lifetime Five has changed for new
purchasers, you may be subject to the new charge at the time of such step-up.
Prior to increasing your charge for Highest Daily Lifetime Five upon a step-up,
we would notify you, and give you the opportunity to cancel the automatic
step-up feature.

The Highest Daily Lifetime Five program does not affect your ability to make
withdrawals under your contract, or limit your ability to request withdrawals
that exceed the Highest Daily Annual Income Amount. Under Highest Daily
Lifetime Five, if your cumulative withdrawals in a contract year are less than
or equal to the Highest Daily Annual Income Amount, they will not reduce your
Highest Daily Annual Income Amount in subsequent contract years, but any such
withdrawals will reduce the Highest Daily Annual Income Amount on a
dollar-for-dollar basis in that contract year.

If, cumulatively, you withdraw an amount less than the Highest Daily Annual
Income Amount in any contract year, you cannot carry-over the unused portion of
the Highest Daily Annual Income Amount to subsequent contract years.

Examples of dollar-for-dollar and proportional reductions, and the Highest
Quarterly Step-Up are set forth below. The values depicted here are purely
hypothetical, and do not reflect the charges for the Highest Daily Lifetime
Five Benefit or any other fees and charges. Please assume the following for all
three examples:

. The contract is purchased on December 1, 2006

. The Highest Daily Lifetime Five Benefit is elected on March 5, 2007.

Dollar-for-dollar reductions

On May 2, 2007, the Protected Withdrawal Value is $120,000, resulting in a
Highest Daily Annual Income Amount of $6,000 (5% of $120,000). Assuming $2,500
is withdrawn from the contract on this date, the remaining Highest Daily Annual
Income Amount for that contract year (up to and including December 1, 2007)

is $3,500. This is the result of a dollar-for-dollar reduction of the Highest
Daily Annual Income Amount -- $6,000 less $2,500 = $3,500.

Proportional reductions

Continuing the previous example, assume an additional withdrawal of $5,000
occurs on August 6, 2007 and the contract value at the time of this withdrawal
is $110,000. The first $3,500 of this withdrawal reduces the Highest Daily
Annual Income Amount for that contract year to $0. The remaining withdrawal
amount ($1,500) reduces the Highest Daily Annual Income Amount in future
contract years on a proportional basis based on the ratio of the excess
withdrawal to the contract value immediately prior to the excess withdrawal.
(Note that if there were other withdrawals in that contract year, each
withdrawal would result in another proportional reduction to the Highest Daily
Annual Income Amount).

Here is the calculation:

Contract value before withdrawal $110,000.00
Less amount of "non" excess withdrawal -$ 3,500.00
Contract value immediately before excess withdrawal of $1,500 $106,500.00

Excess withdrawal amount, $ 1,500.00
divided by contract value immediately before excess withdrawal $106,500.00
Ratio 1.41%

Highest Daily Annual Income Amount $ 6,000.00
Less ratio of 1.41% -$ 84.51
Highest Daily Annual Income Amount for future contract years $ 5,915.49

Highest Quarterly Step

On each contract anniversary date, the Highest Daily Annual Income Amount is
stepped-up if 5% of the highest quarterly value since your first withdrawal (or
last contract anniversary in subsequent years), adjusted for excess withdrawals
and additional purchase payments, is greater than the Highest Daily Annual
Income Amount, also adjusted for excess withdrawals and additional purchase
payments.

Continuing the same example as above, the Highest Daily Annual Income Amount
for this contract year is $6,000. However, the excess withdrawal on August 6th
reduces this amount to $5,915.49 for future years (see above). For the next
contract year, the Highest Daily Annual Income Amount will be stepped-up if 5%
of the highest quarterly contract value, adjusted for withdrawals, is greater
than $5,915.49. Here are the calculations for determining the quarterly values.
Only the June 1 value is being adjusted for excess withdrawals, as the
September 1 and December 1 valuation dates occur after the excess withdrawal on
August 6.

Highest Quarterly
Value (adjusted with Adjusted Annual Income
withdrawal and Amount (5% of the
Date* Account value premium)** Highest Quarterly Value)
----- ------------- -------------------- ------------------------
June 1, 2007 $118,000.00 $118,000.00 $5,900.00
August 6, 2007 $120,000.00 $112,885.55 $5,644.28
September 1, 2007 $112,000.00 $112,885.55 $5,644.28
December 1, 2007 $119,000.00 $119,000.00 $5,950.00

- --------
* In this example, the contract anniversary date is December 1. The quarterly
valuation dates are every three months thereafter -
March 1, June 1, September 1, and December 1. In this example, we do not use
the March 1 date as the first withdrawal took place after March 1. The
contract anniversary date of December 1 is considered the fourth and final
quarterly valuation date for the year.
**In this example, the first quarterly value after the first withdrawal is
$118,000 on June 1, yielding an adjusted Highest Daily Annual Income Amount
of $5,900.00. This amount is adjusted on August 6 to reflect the $5,000
withdrawal. The calculations for the adjustments are:

. The contract value of $118,000 on June 1 is first reduced
dollar-for-dollar by $3,500 ($3,500 is the remaining Highest Daily
Annual Income Amount for the contract year), resulting in an adjusted
contract value of $114,500 before the excess withdrawal.

. This amount ($114,500) is further reduced by 1.41% (this is the ratio
in the above example which is the excess withdrawal divided by the
contract value immediately preceding the excess withdrawal) resulting
in a Highest Quarterly Value of $112,885.55.

The adjusted Highest Daily Annual Income Amount is carried forward to the next
quarterly anniversary date of September 1. At this time, we compare this amount
to 5% of the contract value on September 1. Since the June 1 adjusted Highest
Daily Annual Income Amount of $5,644.28 is higher than $5,600.00 (5% of
$112,000), we continue to carry $5,644.28 forward to the next and final
quarterly anniversary date of December 1. The contract value on December 1 is
$119,000 and 5% of this amount is $5,950. Since this is higher than $5,644.28,
the adjusted Highest Daily Annual Income Amount is reset to $5,950.00

In this example, 5% of the December 1 value yields the highest amount of $
5,950.00. Since this amount is higher than the current year's Highest Daily
Annual Income Amount of $5,915.49 adjusted for excess withdrawals, the Highest
Daily Annual Income Amount for the next contract year, starting on December 2,
2007 and continuing through December 1, 2008, will be stepped-up to $5,950.00.

BENEFITS UNDER HIGHEST DAILY LIFETIME FIVE

. To the extent that your contract value was reduced to zero as a result
of cumulative withdrawals that are equal to or less than the Highest
Daily Annual Income Amount and amounts are still payable under the
Highest Daily Life Income Benefit, we will make an additional payment,
if any, for that contract year equal to the remaining Highest Daily
Annual Income Amount for the contract year. Thus, in that scenario,
the remaining Highest Daily Annual Income Amount would be payable even
though your contract value was reduced to zero. In subsequent contract
years we make payments that equal the Highest Daily Annual Income
Amount as described in this section. We will make payments until the
death of the single designated life. To the extent that cumulative
withdrawals in the current contract year that reduced your contract
value to zero are more than the Highest Daily Annual Income Amount,
the Highest Daily Lifetime Five Benefit terminates, and no additional
payments will be made.

. If annuity payments are to begin under the terms of your contract, or
if you decide to begin receiving annuity payments and there is a
Highest Daily Annual Income Amount due in subsequent contract years,
you can elect one of the following two options:

(1) Apply your contract value to any annuity option available; or
(2) Request that, as of the date annuity payments are to begin, we
make annuity payments each year equal to the Highest Daily Annual
Income Amount. We will make payments until the death of the single
designated life.

We must receive your request in a form acceptable to us at our office.

In the absence of an election when mandatory annuity payments are to begin, we
will make annual annuity payments in the form of a single life fixed annuity
with ten payments certain, by applying the greater of the annuity rates then
currently available or the annuity rates guaranteed in your contract. The
amount that will be applied to provide such annuity payments will be the
greater of:

(1) The present value of the future Highest Daily Annual Income Amount
payments. Such present value will be calculated using the greater of the
single life fixed annuity rates then currently available or the single
life fixed annuity rates guaranteed in your contract; and
(2) The contract value.

. If no withdrawal was ever taken, we will determine the Protected
Withdrawal Value and calculate the Highest Daily Annual Income Amount
as if you made your first withdrawal on the date the annuity payments
are to begin.

OTHER IMPORTANT CONSIDERATIONS

. Withdrawals under the Highest Daily Lifetime Five benefit are subject
to all of the terms and conditions of the contract, including any
CDSC. We take withdrawals pro rata from your variable investment
options and fixed investment options.

. Withdrawals made while the Highest Daily Lifetime Five program is in
effect will be treated, for tax purposes, in the same way as any other
withdrawals under the contract. The Highest Daily Lifetime Five
program does not directly affect the contract value or surrender
value, but any withdrawal will decrease the contract value by the
amount of the withdrawal (plus any applicable CDSC). If you surrender
your contract, you will receive the current surrender value.

. You can make withdrawals from your contract while your contract value
is greater than zero without purchasing the Highest Daily Lifetime
Five Benefit. The Highest Daily Lifetime Five Benefit provides a
guarantee that if your contract value declines due to market
performance, you will be able to receive your Highest Daily Annual
Income Amount in the form of periodic benefit payments.

. You must allocate your contract value in accordance with the then
available investment option(s) that we may permit in order to elect
and maintain the Highest Daily Lifetime Five Benefit.

ELECTION OF AND DESIGNATIONS UNDER THE BENEFIT

For Highest Daily Lifetime Five, there must be either a single owner who is the
same as the annuitant, or if the contract is entity-owned, there must be a
single natural person annuitant. In either case, the annuitant must be at least
55 years old.

Any change of the annuitant under the contract will result in cancellation of
Highest Daily Lifetime Five. Similarly, any change of owner will result in
cancellation of Highest Daily Lifetime Five, except if (a) the new owner has
the same taxpayer identification number as the previous owner, (b) both the new
owner and previous owner are entities, or (c) the previous owner is a natural
person and the new owner is an entity.

Highest Daily Lifetime Five can be elected at the time that you purchase your
contract. We also offer existing owners (i.e., those who have already acquired
their contract) the option to elect Highest Daily Lifetime Five, subject to our
eligibility rules and restrictions.

Currently, if you terminate the Highest Daily Lifetime Five Benefit, you will
(a) not be permitted to re-elect the benefit and (b) will be allowed to elect
the Spousal Lifetime Five Benefit or the Lifetime Five Income Benefit on any
anniversary of the contract date that is at least 90 calendar days from the
date the Highest Daily Lifetime Five Benefit was terminated. We reserve the
right to further limit the election frequency in the future. Before making any
such change to the election frequency, we will provide prior notice to owners
who have an effective Highest Daily Lifetime Five Benefit.

TERMINATION OF THE BENEFIT

You may terminate the benefit at any time by notifying us. If you terminate the
benefit, any guarantee provided by the benefit will terminate as of the date
the termination is effective, and certain restrictions on re-election will
apply as described above. We reserve the right to further limit the frequency
election in the future. The benefit terminates: (i) upon your termination of
the benefit, (ii) upon your surrender of the contract, (iii) upon your election
to begin receiving annuity payments; (iv) upon the death of the designated
life, (v) if both the contract value and Highest Daily Annual Income Amount
equal zero, or (vi) if you fail to meet our requirements for issuing the
benefit.

Upon termination of Highest Daily Lifetime Five, we cease deducting the charge
for the benefit. With regard to your investment allocations, upon termination
we will: (i) leave intact amounts that are held in the variable investment
options, and (ii) transfer all amounts held in the Benefit Fixed Rate Account
(as described below) to your variable investment options, based on your
existing allocation instructions or (in the absence of such existing
instructions) pro rata (i.e. in the same proportion as the current balances in
your variable investment options).

ASSET TRANSFER COMPONENT OF HIGHEST DAILY LIFETIME FIVE

As indicated above, we limit the sub-accounts to which you may allocate
contract value if you elect Highest Daily Value Lifetime Five. For purposes of
this benefit, we refer to those permitted sub-accounts as the "Permitted
Sub-accounts". As a requirement of participating in Highest Daily Lifetime
Five, we require that you participate in our specialized asset transfer
program, under which we may transfer contract value between the Permitted
Sub-accounts and a fixed interest rate account that is part of our general
account (the "Benefit Fixed Rate Account"). The Benefit Fixed Rate Account is
available only with this benefit, and thus you may not allocate purchase
payments to that Account.

Under the asset transfer component of Highest Daily Lifetime Five, we monitor
your contract value daily and, if necessary, systematically transfer amounts
between the Permitted Sub-accounts you have chosen and the Benefit Fixed Rate
Account. Any transfer would be made in accordance with a formula, which is set
forth in the schedule supplement to the endorsement for this benefit (and also
appears in the Appendices to this prospectus). Specifically, each business day,
the formula monitors fluctuations in your variable contract value, your
projected Highest Daily Annual Income Amount, and other factors, relative to
certain "reallocation triggers" to determine whether contract value must be
transferred to or from the Benefit Fixed Rate Account. As you can glean from
the formula itself, a downturn in the securities markets that equals or exceeds
the reallocation trigger level will cause us to transfer some of your variable
contract value to the Benefit Fixed Rate

Account. Moreover, certain market return scenarios involving "flat" returns
over a period of time also could result in the transfer of money to the Benefit
Fixed Rate Account. In deciding how much to transfer, we look at a number of
factors, including the severity of the decline and, based on current values,
how much we would be obligated to pay out if you withdrew the Highest Daily
Annual Income Amount each year for the remainder of your life. Conversely,
appreciation in the securities markets that affects your variable contract
value may cause us to transfer contract value from the Benefit Fixed Rate
Account to your Permitted Sub-Accounts. As with a decline, the amount that we
transfer will depend on a number of factors, including the magnitude of the
increase and our estimate of the cumulative Highest Daily Annual Income Amounts
that we would pay out over your lifetime.

While you are not notified when your contract reaches a reallocation trigger,
you will receive a confirmation statement indicating the transfer of a portion
of your contract value either to or from the Benefit Fixed Rate Account. The
formula by which the reallocation triggers operate is designed primarily to
mitigate the financial risks that we incur in providing the guarantee under
Highest Daily Lifetime Five.

Depending on the results of the calculation relative to the reallocation
triggers, we may:

. Not make any transfer; or
. If a portion of your contract value was previously allocated to the
Benefit Fixed Rate Account, transfer all or a portion of those amounts to
the Permitted Sub-accounts, based on your existing allocation
instructions (e.g., asset allocation) or (in the absence of such existing
instructions) pro rata. Amounts taken out of the Benefit Fixed Rate
Account will be withdrawn for this purpose on a last-in, first-out basis
(an amount renewed into a new guarantee period under the Benefit Fixed
Rate Account will be deemed a new investment for purposes of this
last-in, first-out rule); or
. Transfer all or a portion of your contract value in the Permitted
Sub-accounts pro-rata to the Benefit Fixed Rate Account. The interest
that you earn on such transferred amount will be equal to the annual rate
that we have set for that day, and we will credit the daily equivalent of
that annual interest until the earlier of one year from the date of the
transfer or the date that such amount in the Benefit Fixed Rate Account
is transferred back to the Permitted Sub-accounts.

If a significant amount of your contract value is systematically transferred to
the Benefit Fixed Rate Account during periods of market declines or low
interest rates, less of your contract value may be available to participate in
the investment experience of the Permitted Sub-accounts if there is a
subsequent market recovery. Under the reallocation formula that we employ, it
is possible that a significant portion of your contract value may be allocated
to the Benefit Fixed Rate Account.

ADDITIONAL TAX CONSIDERATIONS FOR QUALIFIED CONTRACTS/ARRANGEMENTS

If you purchase a contract as an investment vehicle for "qualified"
investments, including an IRA, SEP-IRA, Tax Sheltered Annuity (or 403(b)) or
employer plan under Code Section 401(a), the minimum distribution rules under
the Code require that you begin receiving periodic amounts from your contract
beginning after age 70 1/2. For a Tax Sheltered Annuity or a 401(a) plan for
which the participant is not a greater than 5 percent owner of the employer,
this required beginning date can generally be deferred to retirement, if later.
Roth IRAs are not subject to these rules during the owner's lifetime. The
amount required under the Code may exceed the Highest Daily Annual Income
Amount, which will cause us to increase the Highest Daily Annual Income Amount
in any contract year that required minimum distributions due from your contract
are greater than such

amounts. In addition, the amount and duration of payments under the annuity
payment and death benefit provisions may be adjusted so that the payments do
not trigger any penalty or excise taxes due to tax considerations such as
minimum distribution requirements.

SECTION 8 (subsection entitled "Insurance and Administrative Charges")

We replace the first sentence of the first paragraph concerning the charges for
Lifetime Five and Spousal Lifetime Five with the following: "We impose an
additional charge of 0.60% annually if you choose the Lifetime Five Income
Benefit or the Highest Daily Lifetime Five Benefit, and an additional charge of
0.75% annually if you choose the Spousal Lifetime Five Income Benefit."

APPENDIX B: Selecting The Variable Annuity That's Right For You

In the product comparison chart, we revise the line item (and accompanying
footnote) concerning Living Benefits to reflect that Highest Daily Lifetime
Five is available under Strategic Partners FlexElite 2, Strategic Partners
Annuity One 3 and Strategic Partners Plus 3.

We add the following as Appendix C:

Appendix C

Asset Transfer Formula Under Highest Daily Lifetime Five Benefit

We set out below the current formula under which we may transfer amounts
between the variable investment options and the Benefit Fixed Rate Account. As
discussed in Section 5, we reserve the right to modify this formula with
respect to those who elect Highest Daily Lifetime Five in the future. However,
upon your election of Highest Daily Lifetime Five, we will not alter the asset
transfer formula that applies to your contract.

Terms and Definitions referenced in the calculation formula:

. C\\u\\ - the upper target is established on the Effective Date and is not
changed for the life of the guarantee.
. C\\t\\ - the target is established on the Effective Date and is not
changed for the life of the guarantee.
. C\\l\\ - the lower target is established on the Effective Date and is not
changed for the life of the guarantee.
. L - the target value as of the current business day.
. r - the target ratio.
. a - the factors used in calculating the target value. These factors are
established on the Effective Date and are not changed for the life of the
guarantee.
. Q - age based factors used in calculating the target value. These factors
are established on the Effective Date and are not changed for the life of
the guarantee.
. V - the total value of all Sub-accounts in the annuity.
. F - the total value of all Benefit Fixed Rate Account allocations.
. I - the Income Value prior to the first withdrawal. The Income Value is
equal to what the Annual Income Amount would be if the first withdrawal
were taken on the date of calculation. After the first withdrawal the
Income Value equals the greater of the Annual Income Amount, the
quarterly step-up amount times the Annual Income Percentage, and the
contract value times the Annual Income Percentage.

. T - the amount of a transfer into or out of the Benefit Fixed Rate
Account.
. I% - Annual Income Amount percentage. This factor is established on the
Effective Date and is not changed for the life of the guarantee.

Target Value Calculation:
On each business day, a target value (L) is calculated, according to the
following formula. If the variable contract value (V) is equal to zero, no
calculation is necessary.

L = I * Q * a

Transfer Calculation:
The following formula, which is set on the Effective Date and is not changed
for the life of the guarantee, determines when a transfer is required:

Target Ratio r = (L - F) / V

. If r (greater than) C\\u\\, assets in the Sub-accounts are transferred
to Benefit Fixed Rate Account.

. If r (less than) C\\l\\, and there are currently assets in the Benefit
Fixed Rate Account (F (greater than) 0), assets in the Benefit Fixed Rate
Account are transferred to the Sub-accounts.

The following formula, which is set on the Effective Date and is not changed
for the life of the guarantee, determines the transfer amount:

T ={Min(V, [L - F - V * Ct] / (1-Ct))} T(greater than)0, Money moving from the Sub-accounts
to the Benefit Fixed Rate Account
T ={Min(F, [L - F - V * Ct] / (1-Ct))} T(less than)0, Money moving from the Benefit Fixed
Rate Account to the Sub-accounts]

*** * * * * * * * * *

Change With Regard To Maximum Annuity Date

In the Section 3 of each prospectus, under "Payment Provisions", we add the
following to the end of the first paragraph:

For contracts issued on or after November 20, 2006, your annuity date must be
no later than the first day of the month next following the owner's 95/th/
birthday (unless we agree to another date).

This prospectus supplement is intended to amend the prospectus for the
annuity you own, and is not intended to be a prospectus or offer for any
annuity listed here that you do not own.

September 12, 2006

Ms. Sally Samuel, Esq.
Office of Insurance Products
Division of Investment Management
United States Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549

RE: Responses to your comments to Post-effective amendment under Rule 485(a)
under the Securities Act of 1933 to Form N-4 registration statement, file no.
333-75702

Dear Ms. Samuel:

As you know, last July we filed a post-effective amendment under Rule 485(a) to
the above-referenced registration statement to add a new living benefit called
"Highest Daily Lifetime Five" (the "Benefit"). We plan to add the Benefit to
other variable annuities of Pruco Life Insurance Company ("Pruco Life"), and to
that end, sought the Staff's permission to add the Benefit to those other
annuities in filings made under Rule 485 (b)(1)(vii). In this filing, we
respond to your comments on the "model" Rule 485(a) filing we made in July. We
also enclose a copy of the revised draft supplement for your review.

As counsel to the registrant, I represent that the instant filing does not
contain other disclosures that would render it ineligible to rely on Rule
485(b).

We set out below your comments on the "model" filing and our responses thereto.

1. Comment: You requested that in both the section of the supplement that
summarizes the Benefit, and in the section that discusses the Benefit
in detail, we describe in more detail how the asset transfer formula
operates. In addition, you asked that the formula itself be set forth
in the prospectus. Finally, you asked that we disclose that the
formula applicable to a given annuity owner who selects the Benefit
cannot be changed for that owner.

Response: We have expanded our discussion of the Benefit formula in the section
of the supplement entitled "Asset Transfer Component of Highest Daily Lifetime
Five", and have set forth the formula itself in a new appendix to the
prospectus. Please note that we have excluded from what is set forth in the
appendix certain aspects of the formula's operation that are proprietary. The
formula, as it appears in the appendix, is the same as

what we set forth in the schedule supplement to the annuity contract. We think
that what we propose to set forth in the appendix will provide investors with a
good sense of how the formula works. In the Summary section of the supplement,
we have included a cross reference to that additional disclosure.

2. Comment: As you know, Strategic Partners FlexElite, Strategic Partners
Annuity One 3, and Strategic Partners Plus 3 allow the annuity owner
to select certain combinations of living benefits and death benefits.
Each such living benefit and death benefit carries a discrete charge,
and for some time, we have indicated in the fee table what the total
charge for each of the permissible combinations of such benefits would
be. We think that such a presentation assists the investor by showing
explicitly what those charges amount to, when added. You asked that we
revise the current fee table presentation to set forth the individual
living benefit and death benefit charges, rather than adding them. For
Strategic Partners Annuity One 3 (contract without credit), you also
asked whether the charges listed are the maximum charges.

Response: We have broken out those charges as requested, and for the other
Pruco Life and PLNJ variable annuities that are not adding the Benefit, but
would be affected by this comment, will make comparable changes in the next,
regularly-scheduled post-effective amendment. With regard to Strategic Partners
Annuity One 3 (contract without credit), the 1.40% charge for the base death
benefit is the charge that we impose currently. We do not have the contractual
ability to raise that charge for in-force contracts. As part of our contract
filings for this product with certain states, however, we have filed a
"Memorandum of Variability", in which we set forth a maximum charge of 2.00%
for the base death benefit (contract without credit). If we were to increase
the charge for the base death benefit, that increased charge would apply only
to newly-issued contracts. However, we have no present intention of increasing
the 1.40% charge. Given that we do not currently impose a 2.00% charge, and
have no plans to do so in the foreseeable future, we do not think it would be
useful to disclose the 2.00% charge in the fee table.

3. Comment: You asked that we add disclosure to clarify how long an
annuity owner who has terminated the benefit must wait before electing
Lifetime Five or Spousal Lifetime Five.

Response: We have added that disclosure.

4. Comment: You asked that in the paragraph beginning with "We offer a
benefit . . ."), we cross reference other key sections that provide
greater detail about the Benefit. You also asked that we discuss in
more detail which benefits remain in effect if the contract value
becomes zero.

Response: We have added clarifying disclosure.

5. Comment: With regard to the section concerning the Highest Quarterly
Auto- Step-Up, you asked whether the reference to "business day"
should be capitalized. You also asked us to clarify the reference to
"later years", and to indicate how often the auto-step calculation is
done.

Response: Business day is a term that is defined in the Glossary. It is
distinct from the terms "Current Business Day" and "Prior Business Day" that
are used solely in connection with the description of Protected Withdrawal
Value under Highest Daily Lifetime Five. In other parts of the prospectus, we
have not capitalized "business day", and thus have not capitalized that term
here. We have added disclosure clarifying the reference to "later years." As
indicated in the current draft supplement, we determine whether an auto-step up
occurs "on each contract anniversary."

6. Comment: With regard to the mathematical examples in the supplement,
you asked us to explain the relevance of the March 5, 2007 date and
the May 2, 2007 date. You also asked us to add disclosure explaining
that a proportional reduction can occur more than once.

Response: March 5, 2007 is the date that the Benefit is elected. May 2, 2007 is
the date of the first withdrawal. Thus, it is on May 2, 2007 that the amount of
the Protected Withdrawal Value is "locked in." With regard to your other
comment, we have added clarifying disclosure.

7. Comment: You asked about the "default" annuity option that is
associated with the Benefit. In addition, you asked whether a variable
annuity payout option is available.

Response: As indicated in the current draft supplement, in the absence of an
election when mandatory annuity payments are to begin, we will make annual
annuity payments in the form of a single life fixed annuity with ten payments
certain. Because there are ten years' worth of payments guaranteed, it is not
possible for the payee to receive only one payment. With regard to this annuity
product, we offer only fixed annuity payout options--not variable annuity
payout options.

8. Comment: In the section entitled "Elections of and Designations Under
the Benefit", you asked us to clarify that in-force contracts can
elect the Benefit.

Response: We have added clarifying disclosure.

9. Comment: in certain sections of the supplement, you asked us to
clarify the distinction between "existing allocation instructions" and
"otherwise pro rata".

Response: We have made that clarification.

We represent and acknowledge that:

. the depositor and the registrant are responsible for the adequacy and
accuracy of the disclosure in the instant filing; and
. staff comments, or changes to disclosure in response to staff comments
in the filings reviewed by the staff, do not foreclose the Commission
from taking any action with respect to the instant filing; and
. the depositor and the registrant may not assert staff comments as a
defense in any proceeding initiated by the Commission or any person
under the federal securities laws of the United States.

If these responses are acceptable to you, we will make the changes in
subsequent Rule 485(b) filings. Because this prospectus supplement also will be
added to the Form S-3 registration statements for the companion MVA options, we
also will file those Form S-3s, along with requests for acceleration. We
appreciate your attention to this filing.

Sincerely,

C. Christopher Sprague