W. THOMAS CONNER
DIRECT LINE: 202.383.0590
E-mail: thomas.conner@sutherland.com


                                          March 27, 2009




Alison White, Esq.
U.S. Securities and Exchange Commission
100 F Street, N.E.
Washington, DC 20549

     Re: MetLife Investors USA Insurance Company
         MetLife Investors USA Separate Account A
         Post-Effective Amendment on Form N-4
         File Nos. 333-125757/811-03365

Dear Ms. White:

On behalf of MetLife Investors USA Insurance Company ("MLI USA" or "the
Company") and its separate account, MetLife Investors USA Separate Account A,
we are responding to the comments that you orally provided to us on March 11,
2009 in connection with the Marquis Portfolios/ /post-effective amendment filed
on February 3, 2009 pursuant to paragraph (a)(1) of Rule 485 under the
Securities Act of 1933 (the "1933 Act"). Each of the Staff's comments is set
forth below, followed by the Company's response. To the extent that a response
indicates that the Company proposes revised disclosure, the revised prospectus
pages are attached.

   1. Comment: Please note that we will need time to review the updated
   portfolio expenses, expense examples, and appendices prior to the 485(b)
   filing.

   Response: The Company intends to submit the updated information in draft
   form to the Staff via EDGAR submission as soon as it is available, but prior
   to the filing of the post-effective amendment pursuant to paragraph (b) of
   Rule 485 under the 1933 Act.

   2. Comment: Please note that if you qualify for and intend to rely upon the
   exemption provided by Rule 12h-7 under the Securities Exchange Act of 1934,
   you must include a statement to that effect in the prospectus.

   Response: The Company understands that various trade groups are in
   discussions with the Staff regarding Rule 12h-7's applicability to variable
   products. The Company intends to wait until those discussions are concluded
   prior to adding such disclosure in the post-effective amendment to be filed
   in April as may ultimately be required.



Alison White, Esq.
March 27, 2009
Page 2

   3. Comment: Please revise the black-lined disclosure on page 55 to be
   consistent with plain English principles.

   Response: The Company has revised the black-lined disclosure to be
   consistent with plain English principles and has attached revised disclosure.

   4. Comment: Please provide Tandy representations.

   Response: The Company will submit a letter under separate cover
   acknowledging the Tandy representations.

                                     * * *

We hope that you will find these responses satisfactory. If you have any
questions or comments, please contact the undersigned at (202) 383-0590 or Lisa
Flanagan at (202) 383-0873.

                                                  Sincerely,

                                                  /s/ W. Thomas Conner
                                                  ------------------------------
                                                  W. Thomas Conner


cc: Michele Abate, Esq.
    John Richards, Esq.
    Lisa Flanagan, Esq.