Lincoln Benefit Life Company

1221 N Street, Suite 200

Lincoln, Nebraska 68508

Phone: (888) 674-3667

March 30, 2020

U.S. Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

RE:    Acceleration Request

Post-Effective Amendment No. 2 to Registration Statement on Form S-1

File No. 333-224097

Principal Underwriter: Allstate Distributors, LLC

Members of the Commission:

Pursuant to Rule 461 of Regulation C under the Securities Act of 1933, acceleration of the above-referenced Post-Effective Amendment No. 2 to the Registration Statement on Form S-1 is hereby requested to April 27, 2020.

Please direct any questions or comments to me at (203) 653-3897. Thank you.

Very truly yours,

LINCOLN BENEFIT LIFE COMPANY

/s/ Megan Curoe

Megan Curoe

Assistant Secretary