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1301 K Street, N.W.
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Direct Phone: +1 202 414 9208 Washington, D.C. 20005-3373
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Fax +1 202 414 9299
reedsmith.com
September 3, 2014
VIA EDGAR
Sonny Oh
Division of Investment Management
Insured Investments Office
Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549
METLIFE ACCUMULATION ANNUITY: FORM N-4 REGISTRATION STATEMENT (333-197658) OF
METLIFE OF CT SEPARATE ACCOUNT ELEVEN FOR VARIABLE ANNUITIES (THE "REGISTRATION
STATEMENT")
Dear Mr. Oh:
On behalf of MetLife Insurance Company of Connecticut and MetLife of CT Separate
Account Eleven for Variable Annuities, please find attached a revised prospectus
for the above-referenced Registration Statement that reflects recent updates to
the contract form for the MetLife Accumulation Annuity contracts. Following the
initial filing of the Registration Statement on July 25, 2014, the contract form
for MetLife Accumulation Annuity was updated to add a termination provision
(termination upon partial annuitization) to the return of death benefit rider,
which is automatically included with the product. The revised prospectus may
also reflect other minor updates made to the contract form. In addition, because
the PGR (GMAB) feature is not 'RMD-friendly', disclosure has been added to the
prospectus to the effect that withdrawals, including RMD withdrawals, cause
proportionate reductions to the benefit base, and therefore the contract may not
be appropriate for circumstances where RMDs will begin before the PGR End Date,
when the rider pays out if a benefit is due.
The registrant will file at least one pre-effective amendment to the
Registration Statement prior to requesting acceleration of the effective date of
the Registration Statement. The registrant will include the changes set forth
in the attached prospectus in the version of the prospectus that is contained in
the first pre-effective amendment filed by the registrant.
Please contact the undersigned at 202.414.9208 or Peggy Heminger at 412.288.7204
with any questions.
Very truly yours,
NEW YORK . LONDON . HONG KONG . CHICAGO . WASHINGTON, D.C. . BEIJING . PARIS
.. LOS ANGELES . SAN FRANCISCO . PHILADELPHIA . SHANGHAI . PITTSBURGH . HOUSTON
.. SINGAPORE . MUNICH . ABU DHABI . PRINCETON . NORTHERN VIRGINIA . WILMINGTON
.. SILICON VALLEY . DUBAI . CENTURY CITY . RICHMOND . GREECE KAZAKHSTA
Sonny Oh
(September 3, 2014) [LOGO OF REEDSMITH]
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/s/ W. Thomas Conner
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W. Thomas Conner
WC:amo
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