CORRESP

         Addendum 1 to Correspondence filed on EDGAR on January 25, 2008

 Page GMI-13 of the prospectus will be modified as follows:

 Your Right to Revoke (Free Look Period)


 You may cancel your contract within ten days after you receive it by returning
 it to our Administrative Office by mail, postmarked within the ten-day period.
 We will extend the ten day period if required by state law. If you cancel your
 contract, we'll return your contribution net of any investment performance and
 applicable charges, which may be more or less than your original contribution
 depending upon the investment experience of the Investment Options you
 selected. You bear the investment risk during the ten-day period, as well as
 any fees and charges incurred during the period your contract is in force. See
 Part 4 for more discussion of the fees and charges. In some states, the law
 requires that we return the amount of your contribution; in that case, we
 return the greater of the Account Value or your contribution.


 Page GMI-24 of the prospectus will be modified as follows:

Guaranteed Rate Options

We offer GROs with Guarantee Periods of two, three, five, seven and ten years.
Each GRO matures at the end of the Guarantee Period you have selected. We can
change the Guarantee Periods available from time to time. Each contribution or
transfer to a GRO establishes a new GRO for the Guarantee Period you choose at
the guaranteed interest rate that we declare as the current rate (Guaranteed
Interest Rate). When you put a contribution into a GRO, a Guaranteed Interest
Rate is locked in for the entire Guarantee Period you select. We credit interest
daily at an annual effective rate equal to the Guaranteed Interest Rate. The
Guaranteed Interest Rate will never be less than the minimum interest rate
stated on the schedule page of your contract, which will never be less than 1%.

COVER

Correspondence Filing VIA EDGAR

January 25, 2008

William J. Kotapish, Esq.
Chief, Office of Insurance Products
Division of Investment Management
Securities and Exchange Commission
100 F. Street N.E.
Washington, D.C. 20549

 RE: Separate Account I of Integrity Life Insurance Company
     Response to SEC comments on Amendment Number 30 to Registration Statement
     File Numbers 033-56654 and 811-04844, filed on December 5, 2007

Dear Mr. Kotapish:

This letter is in response to comments from the Securities and Exchange
Commission (Commission) staff (Staff) received on January 23, 2008, on
Post-Effective Amendment Number 30 to the above referenced registration
statement of Integrity Life Insurance Company (Integrity). The Staff's comments
are restated below and each one has been addressed.

1.   In the section of the prospectus titled "Your Right to Revoke," clarify
     that you will return the greater of the amount required by state law or the
     Account Value. Done. See Addendum 1 to this letter, which contains the
     relevant language that will be added to the prospectus.

2.   In the section of the prospectus titled "Guaranteed Return Options," add
     the minimum rate. Done. See Addendum 1 to this letter, which contains the
     relevant language that will be added to the prospectus. After further
     discussion with the actuarial department and the interest rate committee,
     we determined that we are able to disclose a minimum interest rate and will
     not need to provide an indexing formula.

Registrant will incorporate the items contained in Addendum 1 to this letter in
the prospectus and file the revised prospectus with an amendment under Section
485(b) of the Securities Act of 1933 on or about February 14, 2008, subject to
any additional comments the Staff may have. We hope these responses address the
Staff's concerns.

In connection with the forgoing we acknowledge that: (i) Integrity is
responsible for the adequacy and accuracy of the disclosure in its registration
statements; (ii) the comments of the Commission's staff, or changes to
disclosures in the registration statements in response to the comments of the
Commission's staff does not foreclose the Commission from taking any action with
respect to the registration statements; and (iii) Integrity may not assert the
comments of the Commission's staff as a defense in any proceeding initiated by
the Commission or any person under the federal securities laws of the United
States.

If there are any questions, please do not hesitate to call me at 513-629-1854.

                                            Sincerely,

                                            \s\ Rhonda S. Malone
                                            Associate Counsel - Securities
                                            Western & Southern Financial Group

Copy:    Alison T. White, Esq. with enclosure, via overnight mail
         Michael Berenson, Esq. via electronic mail