Richard H. Kirk Vice President, Corporate Counsel
	The Prudential Insurance Company of America 751 Broad Street, Newark, NJ 07102-3777 Tel 203-925-3707 richard.kirk@prudential.com

September 16, 2022

VIA EDGAR

Securities and Exchange Commission

100 F Street, N.E.

Washington, DC 20549

Re:    Initial Registration Statement on Form S-3

    Pruco Life Insurance Company ("Registrant")

Members of the Commission:

Enclosed for filing on behalf of the above-referenced Registrant is an initial Registration Statement on Form S-3.

The purpose of the S-3 filing is to register the Prudential FlexGuard® Income Select Index-Linked and Variable Annuity B Series. The Annuity will offer contract owners the ability to allocate their premium payment to index-linked crediting strategies as well as a variable investment subaccount under certain circumstances. We are also filing an initial Registration Statement for this Annuity on Form N-4 on behalf of Pruco Life Flexible Premium Variable Annuity Account.

If you have any questions, please call me at (203) 925-3707.

Very truly yours,

/s/ Richard H. Kirk

Richard H. Kirk

Vice President, Corporate Counsel