April 9, 2009

VIA EDGAR

The United States Securities and

   Exchange Commission

Judiciary Plaza

450 Fifth Street NW

Washington, D.C. 20549-0506

Re:                          Nationwide Life Insurance Company

SEC File No. 333-133163

CIK 0000205695

Dear Ms. Marquigny:

On behalf of the registrant, please accept this filing of Post-effective Amendment No. 10 to the Registration Statement on Form S-1 for the offering of guaranteed term options (GTOs) with a market value adjustment feature.

The purpose of this filing is to update all references to the latest annual report on Form 10-K (filed on March 2, 2009; 1933 Act No. 002-64559), which is incorporated into the registration statement by reference.  Other changes have also been made with the intent of clarifying the disclosure.  These changes are noted in the electronic redlined copies.  The materiality of the disclosure changes is consistent with the materiality of changes that would be filed pursuant to Rule 485(b).

We respectfully request an effective date of May 1, 2009.  Please call me at (614) 677-2216 with your questions or comments.

Sincerely,

/s/ Holly J. Hunt

Holly J. Hunt

Senior Counsel

Nationwide Life Insurance Company

cc:           File