FROM: Pitts, Patrice
SENT: Monday, December 05, 2011 4:14 PM
TO: 'Oh, Min S.'
SUBJECT: Simple Solutions Revised Follow-up
IMPORTANCE: High

The attached marked pages incorporate prospectus disclosure revisions made in
response to the follow-up comments that you provided to me by telephone on
Friday, December 5. For your convenience, each follow-up comment is set forth
below.

    .  Add disclosure to the "Highlights" section to the effect that payments
       under the Lifetime Withdrawal Guarantee rider are subject to the
       claims-paying ability of the insurance company and are not guaranteed by
       another party--See attached page 5.

    .  Add disclosure that clarifies why the Remaining Guaranteed Withdrawal
       Amount is important to a contract owner--See attached page 34.

    .  Add disclosure that indicates what happens if account value declines to
       zero because of market performance--See attached pages 35-36. The first
       and second "bullet points" under "It is important to note" now both
       address what happens if account value declines to zero because of market
       performance.

    .  Add disclosure regarding the impact that termination for low account
       value will have on the living benefit rider--Each registrant
       acknowledges the SEC staff's comment, and respectfully declines to add
       the requested disclosure. As discussed, to ensure that a consistent
       approach can be developed across all riders, and for purposes of
       securities, insurance and other laws, MetLife Investors USA Insurance
       Company ("MLI") and First MetLife Investors Insurance Company ("FMLI")
       continue to believe strongly that they must evaluate the interplay of
       each of their riders on their right to to terminate a contract for low
       account value. MLI and FMLI respectfully submit that analyzing a single
       rider, the Lifetime Withdrawal Guarantee, in isolation is not
       productive. Accordingly, each registrant will continue to consider the
       consequences of a contract termination (for low account value) on this
       and its other living benefit riders, from a business and legal
       standpoint and, as appropriate, revise the disclosure in its respective
       May 1, 2012 post-effective amendment.

Thank you in advance for your prompt attention to this matter.

PATRICE M. PITTS | COUNSEL

SUTHERLAND ASBILL & BRENNAN LLP
1275 Pennsylvania Avenue NW | Washington, DC 20004-2415
202.383.0548 direct | 202.637.3593 facsimile
patrice.pitts@sutherland.com | www.sutherland.com
----------------------------   ------------------

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12-5 Simple changes.pdf