Richard H. Kirk Vice President, Corporate Counsel
	The Prudential Insurance Company of America 213 Washington Street, Newark, NJ 07102-2917 Tel 203-925-3707 richard.kirk@prudential.com

October 1, 2020

Office of Insurance Products

Division of Investment Management

U.S. Securities and Exchange Commission

100 F Street, N.E.

Washington, DC 20549

Re:	Registration Statement on Form S-3 SEC File No. 333- Pruco Life Insurance Company (“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 October 2, 2020, or as soon thereafter as practicable.

If you have any questions, please call Elizabeth Gioia at 203-402-1624.

Very truly yours,

PRUCO LIFE INSURANCE COMPANY

By: /s/Richard H. Kirk

Richard H. Kirk

Vice President, Corporate Counsel

PRUDENTIAL ANNUITIES DISTRIBUTORS, INC.

By: /s/Lynn K. Stone

Lynn K. Stone

Assistant Secretary