Douglas E. Scully Vice President, Corporate Counsel
	751 Broad Street Newark, NJ 07102-3777 Tel 203-925-6960 douglas.scully@prudential.com

August 29, 2017

Sonny Oh, Esq.

Office of Insurance Products

Division of Investment Management

U.S. Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

RE:    Pruco Life Insurance Company (“Registrant”)

Registration Statements on Form S-3

Dear Mr. Oh:

As requested, I represent that the disclosures included in the following Form S-3 registration statements do not make any material change to existing disclosures. As such, if these Form S-3 registrations pertained to a registered investment company subject to rule 485 under the Securities Act of 1933, they would be eligible for filing under Rule 485(b).

File No. 333-220097

File No. 333-220099

File No. 333-220116

File No. 333-220118

Please call me at (203) 925-6960 if you have any questions.

Very truly yours,

/s/Douglas E. Scully

Douglas E. Scully