Attn:
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Jim B. Rosenberg, Senior Assistant Chief Accountant
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Division of Corporation Finance
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Re:
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W. R. Berkley Corporation
Form 10-K for the Year Ended December 31, 2010
File No. 1-15202
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·
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Berkley is responsible for the adequacy and accuracy of the disclosure in its filings with the SEC;
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·
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Staff comments or changes to disclosure in response to Staff comments do not foreclose the SEC from taking any action with respect to the filings; and
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·
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Berkley may not assert Staff comments as a defense in any proceeding initiated by the SEC or any person under the federal securities laws of the United States.
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cc:
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Mark Brunhofer (SEC)
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Ibolya Ignat (SEC)
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Ira S. Lederman (Berkley)
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Jeffrey S. Hochman (Willkie Farr)
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