Lincoln Benefit Life Company

1221 N Street, Suite 200

Lincoln, Nebraska 68508

Phone: (888) 674-3667

April 15, 2021

U.S. Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

    RE:    Acceleration Request

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

        File No. 333-254874

        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 Registration Statement on Form S-1 is hereby requested to May 1, 2021.

Please direct any questions or comments to me at (312) 824-6394. Thank you.

Very truly yours,

LINCOLN BENEFIT LIFE COMPANY

/s/ Erik Braun

Erik Braun

Chief Financial Officer