Elizabeth L. Gioia Vice President, Corporate Counsel
	The Prudential Insurance Company of America 751 Broad Street Newark, NJ 07102-3777 Tel (203) 402-1624 elizabeth.gioia@prudential.com

December 8, 2025

FILED VIA EDGAR

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C.  20549

Re:

Everlake Life Insurance Company (“Registrant”)

Request for Withdrawal of Post-Effective Amendment No. 1 to the

  Registration Statement on Form N-4

File No. 333-290881

Members of the Commission:

Pursuant to Rule 477 under the Securities Act of 1933, as amended (the “1933 Act”), we hereby respectfully request that the Securities and Exchange Commission (“SEC”) consent to the withdrawal of Post-Effective Amendment No. 1 to the Registration Statement on Form N-4 (File No. 333-290881) together with all exhibits thereto (the “Amendment”) as filed with the SEC on November 7, 2025 (Accession No. 0000352736-25-000045).

Based on discussion with the SEC Staff following the filing of the Amendment, we plan to file a post-effective amendment under paragraph (b) of Rule 485 under the 1933 Act in the future to amend the Registration Statement to conform to the requirements of amended Form N-4 in reliance on Template Filing Relief. For that reason, it is not necessary that the Amendment filed under paragraph (a) of Rule 485 become effective to amend the Registration Statement to conform to the requirements of amended Form N-4. No securities have been sold under the Registration Statement.

If you have any questions regarding this request, please call me at (203) 402-1624.

Very truly yours,

/s/ Elizabeth L. Gioia    

Elizabeth L. Gioia

Vice President, Corporate Counsel

Prudential