Mail Stop 3561

								November 18, 2005

Douglas K. Johnson
President of AMACAR Pacific Corp.,
Administrator of Allstate Life Global Funding
and Allstate Life Global Funding Trusts
6525 Morrison Boulevard, Suite 318
Charlotte, NC 28211

Michael J. Velotta
Senior Vice President,
General Counsel and Secretary
of Allstate Life Insurance Company
3100 Sanders Road
Northbrook, IL 60062

      Re:	Allstate Life Global Funding
      	Allstate Life Insurance Company
		Registration Statement on Form S-3
		Filed October 20, 2005
		File No. 333-129157

Dear Sirs:

	We have reviewed your filing and have the following comments.
Where indicated, we think you should revise your document in
response
to these comments.  If you disagree, we will consider your
explanation as to why our comment is inapplicable or a revision is
unnecessary.  Please be as detailed as necessary in your
explanation.
In some of our comments, we may ask you to provide us with
information so we may better understand your disclosure.  After
reviewing this information, we may raise additional comments.

	Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or any other aspect
of
our review.  Feel free to call us at the telephone numbers listed
at
the end of this letter.


General
1. Please revise to include the information called for by Item
1102
on the cover page of the supplements, using brackets for
information
which will only be known at the time of doing a takedown.  We do
not
understand why a pricing supplement would be necessary for this
asset
class since it is not for any other.
2. Similarly, please revise to include bracketed alternatives
throughout the supplement to the extent possible to provide us
with
the various alternatives that might form part of the structure of
a
takedown.
3. Please confirm that the depositor or issuing entity previously
established, directly or indirectly, by the depositor or any
affiliate of the depositor have been current with Exchange Act
reporting during the last twelve months with respect to asset-
backed
securities involving the same asset class.  Please refer to
General
Instruction I.A.4 of Form S-3.  Also, please provide us with the
CIK
codes for any affiliate of the depositor that has offered a class
of
asset-backed securities involving the same asset class as this
offering.
4. Either include the information called for by Item 1105 or
provide
us with your analysis of why it is not material.
5. Please tell us what information will be in your Form 10-Ds.
6. Also please confirm that your 10-K will contain the information
required by Item 1122.
7. Please note that our comments to either the base prospectus
and/or
the supplements should be applied universally, if applicable.
Accordingly, if comments issued for one apply to another, make
conforming revisions as appropriate.
8. Please clarify which person or entity is responsible for the
management or collection of the pool assets or making allocations
or
distributions to holders of the asset-backed securities, and
provide
the disclosure required by Item 1108 of Regulation AB.

9. Please tell us how you intend to provide for an annual report
on
assessment of compliance with servicing criteria for asset-backed
securities as well as an attestation report from a registered
public
accounting firm pursuant to Exchange Act Rule 15d-18 and Item 1122
of
Regulation AB.  See also Item 1123 of Regulation AB.  Please note
that all of the required reports must be filed as exhibits to the
annual report on Form 10-K.
10. Please be advised that if a trust is formed prior to the
effectiveness of the registration statement, it must sign the
registration statement.
11. If you intend to issue securities with this registration
statement shortly after effectiveness, include in the last pre-
effective amendment a prospectus supplement which contains all
information relating to the offering which is known or reasonably
available at that time.  File unqualified tax and legality
opinions,
and related consents, pre-effectively with respect to any proposed
immediate takedown.

Prospectus Supplement - Secured Medium Term Notes

General
12. Please include the word "callable" in the title of the
securities, pursuant to Item 1113(f)(2), if early redemption is
available for any reason.

Summary, page S-3
Redemption and Repayment, page S-8
13. Please advise us that you will appropriately caption
"callable"
securities in the Prospectus Supplement and Pricing Supplement and
that you will discuss them in the base prospectus under the
correct
name if you intend to reserve the right to issue them.

Risk Factors, page S-11
The notes of a series are non-recourse obligations of the issuing
trust, page S-11
14. Please clarify when an event of default under a series of
notes
will constitute an event of default under the funding agreements.
For example, your disclosure under the risk section seems to say
that
only in "certain circumstances" an event of default under the
notes
will not constitute an event of default under the funding
agreement,
while the disclosure on page 22 seems to say that in all but one
circumstance an event of default under the notes will not
constitute
an event of default under the funding agreement.

Floating Rate Notes, page S-51
15. Refer to the last bullet on page S-52.  Please tell us in more
detail how the put option will work and provide your legal
analysis
of how it is consistent with the definition of an asset that
converts
to cash by its own terms and with the staff positions on
exchangeable
securities.  Alternately, delete this feature.

Base Prospectus

Available Information, page 3
16. Please revise to reflect the new address for the SEC public
reference facility: Room 1580, 100 F Street, N.E., Washington,
D.C.
20549.

Administrator of Global Funding and the Trusts, page 10
17. Please provide a brief description of the various
administrative
functions to which AMACAR Pacific Corp. will be responsible as
administrator, or provide a cross-reference to where such
information
can be obtained within the registration statement.

Description of the Funding Notes, page 30
18. Please tell us why you chose to structure the transaction
using
funding notes, and what are the risks and benefits associated with
such a structure.

Insolvency of Allstate Life, page 33
19. Please briefly discuss the limitations, qualifications and
assumptions relied upon by Lord, Bissell & Brook LLP in rendering
its
opinion.


Plan of Distribution, page 42
20. Please add that Allstate Life Insurance Company is a statutory
underwriter of the notes.








Signatures, page II-7
21. If Evelyn Echevarria is performing the functions specified by
the
form requirement for S-3, please indicate each capacity.  If not,
please have the persons performing the functions sign.  See
Instructions 1 and 2 under Signatures for Form S-3.

Exhibits
22. Please note that we may have additional comments upon
reviewing
the exhibits.

* * * * *

	As appropriate, please amend your registration statement in
response to these comments.  You may wish to provide us with
marked
copies of the amendment to expedite our review.  Please furnish a
cover letter with your amendment that keys your responses to our
comments and provides any requested information.  Detailed cover
letters greatly facilitate our review.  Please understand that we
may
have additional comments after reviewing your amendment and
responses
to our comments.

	We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing to be certain that the
filing includes all information required under the Securities Act
of
1933 and that they have provided all information investors require
for an informed investment decision.  Since the company and its
management are in possession of all facts relating to a company`s
disclosure, they are responsible for the accuracy and adequacy of
the
disclosures they have made.

	Notwithstanding our comments, in the event the company
requests
acceleration of the effective date of the pending registration
statement, it should furnish a letter, at the time of such
request,
acknowledging that:

* 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;

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

* the company 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.

      In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in connection with our review of
your
filing or in response to our comments on your filing.

	We will consider a written request for acceleration of the
effective date of the registration statement as confirmation of
the
fact that those requesting acceleration are aware of their
respective
responsibilities under the Securities Act of 1933 and the
Securities
Exchange Act of 1934 as they relate to the proposed public
offering
of the securities specified in the above registration statement.
We
will act on the request and, pursuant to delegated authority,
grant
acceleration of the effective date.

	We direct your attention to Rules 460 and 461 regarding
requesting acceleration of a registration statement.  Please allow
adequate time after the filing of any amendment for further review
before submitting a request for acceleration.  Please provide this
request at least two business days in advance of the requested
effective date.

	You may contact John Stickel at (202) 551-3324 or me at (202)
551-3755 if you have any questions.


								Sincerely,



								Max A. Webb
								Assistant Director

cc:	Via Facsimile (212) 649-9495
	John M. Schwolsky
	LeBoeuf, Lamb, Greene & MacRae LLP
	125 West 55th Street
	New York, NY 10019
Allstate Life Global Funding
Allstate Life Insurance Company
November 18, 2005
Page 1