RW 1 b66028a1rw.txt METROPOLITAN LIFE SEPARATE ACCOUNT UL 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Account UL (the "Account"), we hereby request that the above-referenced registration statement filed on Form N-6 be withdrawn, pursuant to Rule 477 under the Securities Act of 1933, as amended (the "1933 Act").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.