[METLIFE LETTERHEAD]

First MetLife Investors Insurance Company
200 Park Avenue
New York, NY 10166

VIA EDGAR TRANSMISSION
----------------------

September 12, 2008

Mr. Michael Kosoff
Division of Investment Management
Office of Insurance Products
U.S. Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549-0506

RE: PRE-EFFECTIVE AMENDMENT NO. 2 TO REGISTRATION STATEMENTS ON FORM N-4 FOR
FIRST METLIFE INVESTORS INSURANCE COMPANY AND FIRST METLIFE INVESTORS VARIABLE
ANNUITY ACCOUNT ONE (FILE NOS. 333-148873 AND 333-148876)

Dear Mr. Kosoff:

On behalf of First MetLife Investors Insurance Company (the "Company") and First
MetLife Investors Variable Annuity Account One (the "Separate Account"), the
Company acknowledges, with respect to the above-referenced filing, that:

     .    should the Commission or the Staff, acting pursuant to delegated
          authority, declare the filings effective, it does not foreclose the
          Commission from taking any action with respect to the filings;

     .    the action of the Commission or the Staff, acting pursuant to
          delegated authority, in declaring the filing effective, does not
          relieve the Company, on behalf of the Separate Account, from its
          full responsibility for the adequacy and accuracy of the disclosure in
          the filings; and

     .    the Company, on behalf of the Separate Account, 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.

If you have any questions or further comments, please call the undersigned at
(617) 578-2857 or Tom Conner at (202) 383-0590.

Sincerely,


/s/ Gregory E. Illson
-----------------------------------------
Gregory E. Illson
Vice President

cc:   W. Thomas Conner, Esq.
      John E. Connolly Jr., Esq.
      Paula J. Minella, Esq.

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