March 27, 2012

U.S. Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549

RE:  Allstate Life Insurance Company of New York
     Registration Statement on Form S-1
     File No. 333-

Members of the Commission:

Submitted for filing under the Securities Act of 1933 is the above-referenced
Registration Statement on Form S-1.

We represent and acknowledge that:

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

     .    The Registrant is responsible for the adequacy and accuracy of the
          disclosure in the filing;

     .    The Staff's comments, the Registrant's changes to the disclosure in
          response to the Staff's comments, or the action of the Commission or
          the Staff, acting pursuant to delegated authority, in declaring the
          filing effective, does not relieve the Registrant from this
          responsibility; and

     .    The Registrant may not assert this action or the Staff's comments as a
          defense in any proceeding initiated by the Commission or any person
          under the federal securities laws of the United States.

Please direct any questions or comments to me at 847-402-7855. Thank you.

Very truly yours,


/s/ Beth A. Brown
-------------------------------
Beth A. Brown

Enclosure

cc: Lynn K. Stone, Esq.
    Prudential Financial