MARY E. THORNTON
DIRECT LINE: 202.383.0698
Internet: mary.thornton@sablaw.com

                                                                   July 11, 2007

VIA EDGAR

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

     RE:  METROPOLITAN LIFE INSURANCE COMPANY
          METROPOLITAN LIFE SEPARATE ACCOUNT UL
          REQUEST FOR WITHDRAWAL OF REGISTRATION STATEMENT ON FORM N-6
          PURSUANT TO RULE 477 (FILE NO. 333-135659; 811-06025)
          ACCESSION NO. 0000950135-06-004234

Commissioners:

     On behalf of Metropolitan Life Insurance Company (the "Company") and
Metropolitan Life Separate Account UL (the "Account"), we hereby request that
the above-referenced registration statement filed on Form N-6 be withdrawn,
pursuant to Rule 477 under the Securities Act of 1933, as amended (the "1933
Act").

     The initial registration statement was filed with the Commission on July
10, 2006. The Company has since determined to not to proceed with this offering
at this time. No securities have been sold with respect to this offering.

     The Account is a registered unit investment trust under the Investment
Company Act of 1940, as amended (the "1940 Act"). The Account is the funding
vehicle for different variable life policies issued by the Company that are
registered separately under the 1933 Act. Therefore, the Account will maintain
its registered status under the 1940 Act.

     If you have any questions or comments concerning this request, please call
me at (202) 383-0698.

                                        Sincerely,

                                        /s/ Mary E. Thornton
                                        Mary E. Thornton

cc: John E. Connolly, Jr.