April 4, 2011

VIA EDGAR

The United States Securities and

   Exchange Commission

100 F Street NE

Washington, D.C. 20549-4644

Subject:      Nationwide Portfolio Innovator

                    Nationwide Life Insurance Company

                    SEC File No. 333-149613

                    CIK 0000205695

Dear Ms. Marquigny:

On behalf of the registrant, please accept this filing of Post-Effective Amendment No. 4 to the Registration Statement on Form S-1 for the offering of Individual Supplemental Immediate Fixed Income Annuity Contracts.

The purpose of this filing is to update all financial information as required by Form S-1.  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 April 29, 2011.  Please call me at (614) 677-6123 with your questions or comments.

Sincerely,

/s/ Benjamin Mischnick

Benjamin Mischnick

Senior Counsel

Nationwide Life Insurance Company

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