ALLSTATE LIFE GLOBAL FUNDING                    ALLSTATE LIFE INSURANCE COMPANY
c/o AMACAR PACIFIC CORP.                              3100 Sanders Road
6525 Morrison Boulevard, Suite 318                   Northbrook, IL 60062
Charlotte, NC 28211


                                  March 13, 2006

Mr. John Stickel
Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549

Re:      Allstate Life Global Funding and Allstate Life Insurance Company
         Registration Statement on Form S-3
         File No. 333-129157

Dear Mr. Stickel:

     Allstate  Life Global  Funding and  Allstate  Life  Insurance  Company (the
"Registrants")  have  filed a  registration  statement  on Form  S-3  (File  No.
333-129157), as amended (the "Registration Statement"),  with the Securities and
Exchange  Commission  (the  "Commission")  under the  Securities Act of 1933, as
amended  (the  "Securities  Act").  In  accordance  with Rule  461(a)  under the
Securities Act, the Registrants  hereby request that the Commission  declare the
Registration Statement, as further amended prior to its effectiveness, effective
under the Securities  Act at 10:00 a.m.,  Eastern Time, on March 15, 2006, or as
soon thereafter as practicable.

     Each of the Registrants hereby confirms that it is aware of its obligations
under the Securities  Act and the  Securities  Exchange Act of 1934, as amended,
with respect to the  distribution  of securities  specified in the  Registration
Statement and acknowledges that:

     o    should the  Commission  or the staff,  acting  pursuant  to  delegated
          authority,  declare the filing  effective,  it does not  foreclose the
          Commission from taking any action with respect to the filing;

     o    the  action  of  the  Commission  or the  staff,  acting  pursuant  to
          delegated  authority,  in  declaring  the filing  effective,  does not
          relieve such Registrant from its full  responsibility for the adequacy
          and the accuracy of the disclosure in the filing; and

     o    such  Registrant may not assert staff comments and the  declaration of
          effectiveness  as  a  defense  in  any  proceeding  initiated  by  the
          Commission  or any person  under the  federal  securities  laws of the
          United States.


                                  Very truly yours,

                                  ALLSTATE LIFE GLOBAL FUNDING

                                  By: AMACAR PACIFIC CORP.,
                                  not in its individual capacity,
                                  but solely as administrator

                                  By:   /s/ DOUGLAS K. JOHNSON
                                        -----------------------
                                  Name:  Douglas K. Johnson
                                  Title:    President


                                  ALLSTATE LIFE INSURANCE COMPANY

                                  By:  /s/ SARAH R. DONAHUE
                                       --------------------
                                  Name:     Sarah R. Donahue
                                  Title:    Assistant Vice President