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W. THOMAS CONNER
DIRECT LINE: 202.383.0590
E-mail: thomas.conner@sutherland.com

                               October 13, 2008

VIA ELECTRONIC MAIL AND EDGAR CORRESPONDENCE SUBMISSION

Michelle Roberts, Esq.
U.S. Securities and Exchange Commission
100 F Street, N.E.
Washington, DC 20549

    Re:  First MetLife Investors Variable Annuity Account One
         Initial Registration Statement on Form N-4
         File Nos. 333-152450/811-08306

Dear Ms. Roberts:

   On behalf of First MetLife Investors Insurance Company ("FMLI") and its
separate account, First MetLife Investors Variable Annuity Account One, we are
providing FMLI's responses to your comments of September 19, 2008 in connection
with the above-referenced initial registration statements filed on July 22,
2008. Each of the Staff's comments is set forth below, followed by FMLI's
response. To the extent that a response indicates that FMLI proposes revised
disclosure, the revised prospectus pages are attached.

1. GENERAL COMMENT

   COMMENT: Please disclose to the Staff whether there are any types of
   guarantees or support agreements with third parties to support any of the
   guarantees under the policy or any of its related riders. If there are not,
   please include a representation in the response letter indicating that there
   are no such agreements and the Depositor will be primarily responsible for
   paying out any guarantees associated with the policy.

   RESPONSE: FMLI entered into a net worth maintenance agreement with its
   parent company, MetLife, Inc ("MetLife"). The agreement is described in the
   Statement of Additional

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Michelle Roberts, Esq.
October 13, 2008
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   Information ("SAI"). The Staff has informed FMLI that it believes that
   MetLife's financial statements need to be included in its SAI. Without
   conceding that MetLife's financial statements are required to be included in
   the SAIs in FMLI's registration statements, FMLI has determined to
   incorporate MetLife's financial statements by reference into the SAI.

2. FEE TABLE (PGS. 10-13)

   COMMENT: (a) The Optional Rider Charges table's use of "(maximum)" needs
   further elaboration. Please insert a clarifying footnote. (See, for example,
   p 55, footnote 3.)

   RESPONSE: (a) FMLI has revised the prospectus to include the following
   footnote: "Certain rider charges may increase upon an Optional Step-Up or
   Optional Reset, but they will not exceed the maximum charges listed in this
   table. (See "Expenses.")."

   COMMENT: (b) Footnote 2 on page 10 contains a typographical
   error--"Withdawal." Please correct.

   RESPONSE: (b) FMLI revised the prospectus to correct the typographical error.

   COMMENT: (c) At the end of the Portfolio Expenses table, there is a
   reference to "Net Total Annual Portfolio Expenses" but there is no column in
   the table with that heading. Should that reference be changed to "Total
   Annual Portfolio Expenses"? In addition, with regard to footnotes to the
   Portfolio Expenses Table that reference the use of "estimated expenses"
   (e.g., footnote 1), the Registrant should disclose why the expenses are
   estimated.

   RESPONSE: (c) FMLI has revised the prospectus to change the reference from
   "Net Total Annual Portfolio Expenses" to "Total Annual Portfolio Expenses."
   In addition, certain fund expenses are estimated because the funds are new.
   FMLI's footnote disclosure is in the format provided by the funds and it is
   consistent with Form N-1A.

3. EXAMPLES (P. 14)

   COMMENT: If applicable, please confirm in your correspondence to the Staff
   that the figures set forth in the Example tables do not reflect the bonus
   credits.

   RESPONSE: FMLI confirms that the figures set forth in the Example tables do
   not reflect the bonus credits.

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Michelle Roberts, Esq.
October 13, 2008
Page 3

4. APPENDIX B

   COMMENT: Please add notes to the Account Values columns indicating how each
   value was calculated.

   RESPONSE: FMLI has revised the prospectus to add notes explaining how the
   values are calculated.

5. APPENDIX C AND APPENDIX D

   COMMENT: Clarify that when a Purchaser makes an excess withdrawal, the
   reduction in account value is calculated using the entire amount of the
   withdrawal and not just the amount that exceeded the Annual Increase
   Amount/Annual Benefit Amount (as applicable).

   RESPONSE: FMLI revised the prospectus to clarify that the reduction in
   account value is calculated using the entire amount of the withdrawal and
   not just the amount that exceeded 6% of the Annual Increase Amount (for the
   GMIB Plus) or the Annual Benefit Payment (for the Lifetime Withdrawal
   Guarantee).

6. MISCELLANEOUS

   COMMENT: (a) Please note that the Staff is reserving the right to comment on
   the Prospectus supplement that was filed as part of this initial
   registration statement as well as a similar supplement that was filed on
   July 17, 2008, under MetLife Investors Separate Account A (Accession
   No. 0001193125-08-152855)

   RESPONSE: (a) Based on Staff comments, FMLI and MetLife Investors USA
   Insurance Company have made the determination to remove the Purchase Payment
   Credit recapture supplement from the filings and not to include any
   reference to the Purchase Payment Credit recapture in the filings.

   COMMENT: (b) Any exhibits, financial statements, and any other required
   disclosure not included in this registration statement must be filed in a
   pre-effective amendment to the registration statement.

   RESPONSE: (b) FMLI will include any exhibits, financial statements, and any
   other required disclosure not included in this registration statement in a
   pre-effective amendment to the registration statement. In addition, FMLI
   will provide the Tandy representations under separate cover.

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Michelle Roberts, Esq.
October 13, 2008
Page 4

   We hope that you will find these responses satisfactory. If you have any
questions or comments, please contact the undersigned at (202) 383-0590 or Lisa
Flanagan at (202) 383-0873.

                                          Sincerely,

                                          /s/ W. Thomas Conner

                                          W. Thomas Conner

  
cc:  Michele Abate, Esq.
     John Richards, Esq.
     Lisa Flanagan, Esq.



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