ALLSTATE LIFE INSURANCE COMPANY
                          LAW AND REGULATION DEPARTMENT
                          3100 Sanders Road , Suite J5B
                         Northbrook, Illinois 60062-7154
                            Email: lwi2m@allstate.com


LISETTE WILLEMSEN                            Writer's Direct Dial 847 402-7366
Assistant Counsel                            Facsimile: 847 402-3781

April 20, 2006

BY EDGAR

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

      Re:   Allstate Life Insurance Company ("Registrant")
            Post-Effective Amendment No. 2 to Form S-3 Registration Statement
            File no. 333-123847
            CIK No. 0000352736
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         On behalf of the above-named Registrant, filed herewith is one
electronically formatted copy of Post-Effective amendment No. 2 ("Amendment") to
the above-referenced registration statement ("Registration Statement") under the
Securities Act.

         To facilitate the Commission staff's review of the Amendment, we submit
the information below.


                              I. Purpose of the Amendment

     The  purpose  of  the  Amendment  is to  add a  corrected  Part  II to  the
registration statement. The Part II replaces the Part II filed in Post-Effective
Amendment No. 1 to the registration  statement on April 5, 2006 ("Post-Effective
Amendment  No. 1"). The Amendment is not intended to amend or delete any part of
the registration statement, except as specifically noted herein.



                         II. Timetable for Effectiveness

         We would appreciate the Commission staff's efforts in processing the
Amendment so that the Registration Statement, as amended, may be declared
effective on May 1, 2006.

     Accordingly,  Registrant  and the  principal  underwriter  hereby  request,
pursuant to Rule 461 under the 1933 Act, that the Commission declare the amended
Registration  Statement  effective  on  May  1,  2006.  To  our  knowledge,   no
distribution  of copies of the  Post-Effective  Amendment or the  prospectus has
been made to prospective  investors.  Distributions  thereof have been made only
for  purposes  of  internal  use  by  Registrant  and  for  regulatory  filings.
Registrant and the principal  underwriter represent that they are aware of their
obligations  under the Act and that their request is consistent  with the public
interest and the protection of investors.

                         III. Registrant's Acknowledgment

         In making its request for acceleration of this Registration Statement,
Registrant hereby acknowledges 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
action of the Commission or the staff, acting pursuant to delegated authority,
in declaring the filing effective, does not relieve Registrant from its full
responsibility for the adequacy and accuracy of the disclosure in the filing;
and Registrant may not assert this action as defense in any proceeding initiated
by the Commission or any person under the federal securities laws of the United
States.

                             -----------------------


         Please direct any question or comment to me at the number set forth
above.




                               Very truly yours,

                             /s/ LISETTE WILLEMSEN
                            -----------------------
                               Lisette Willemsen
                               Assistant Counsel


cc:      Alison White, Esq.
         Securities and Exchange Commission