May 7, 2020

VIA EDGAR

Securities and Exchange Commission

100 F Street, N.E.

Washington, DC 20549

Re:    Pre-Effective Amendment No. 1 to Registration Statement on Form S-3

SEC File No. 333-236098

Prudential Annuities Life Assurance Corporation (Registrant)

Members of the Commission:

Pursuant to Rule 461 of Regulation C under the Securities Act of 1933, acceleration of the above-referenced Registration Statement on Form S-3 is hereby requested to May 12, 2020, or as soon thereafter as practicable.

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

Very truly yours,

PRUDENTIAL ANNUITIES LIFE ASSURANCE CORPORATION

By: /s/Douglas E. Scully

Douglas E. Scully

Vice President

PRUDENTIAL ANNUITIES DISTRIBUTORS, INC.

By: /s/Mary O’Hara

Mary O’Hara

Assistant Secretary