Allianz Life Insurance Company of North America

Stewart Gregg

Senior Securities Counsel

Corporate Legal

5701 Golden Hills Drive

Minneapolis, MN  55416-1297

Telephone:  763-765-2913

Telefax:       763-765-6355

stewart.gregg@allianzlife.com

www.allianzlife.com

VIA EDGAR

February 4, 2013

Re: Allianz Life Insurance Company of North America

Allianz Life Variable Account B

Registration Statement Nos. 333-182989 and 811-05618

Enclosed for filing please find Post-Effective Amendment No. 1 to the Form N-4 Registration Statement for the above-referenced Registrant filed pursuant to Rule 485(a). The primary purpose of this filing is to update disclosure related to the following changes:

·   state specific contract variations,

·   clarification of fees assessed under death benefit option B and Option C,

·   increasing the Annual Increase percentage for Income Protector from 5% to 6%,

·   new Traditional Death Benefit and Quarterly Value Death Benefit based on Determining Life (Lives), and

·   moving information on the original Traditional Death Benefit and Quarterly Value Death Benefit to the appendices.

For the convenience of the staff in reviewing the Registration Statement, a redline copy of the Registration Statement is being sent via email to the Office of Insurance Products of the Division of Investment Management.

Additional required exhibits will be filed by amendment. Manually executed signature pages have been executed prior to the time of this electronic filing and will be retained by the Company for five years.

The Registrant recognizes that it is responsible for the adequacy and accuracy of disclosures in its Registration Statement. The staff's review and changes to the Registration Statement based on staff comments does not bar the Commission from taking future action with respect to the filing. In addition, the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective does not relieve the Registrant from its full responsibility for the adequacy and accuracy of the disclosures in the filing. The Registrant may not assert the staff's review or acceleration of the Registration Statement as a defense in any proceeding initiated by the Commission or any person under the Federal securities laws.

Please contact me with any questions or comments you may have concerning the enclosed. I can be reached at the following address and phone number:

Allianz Life, 5701 Golden Hills Drive, Minneapolis, MN 55416. Telephone: (763)765-2913.

Sincerely,

Allianz Life Insurance Company of North America

By: /s/ Stewart D. Gregg                                           

            Stewart D. Gregg