July 2, 2014

Via EDGAR

Michelle Roberts

Senior Attorney

Securities and Exchange Commission

Division of Investment Management

Office of Insurance Products

100 F Street, NE

Washington D.C. 20549

RE: Principal Life Insurance Company Separate Account B

Registration on Form N-4

Dear Ms. Roberts:

Transmitted herewith for filing is an initial registration statement for the Principal Pivot Series Variable Annuity.

The following Exhibits identified under Item 24 of the Form N-4 will be filed as part of a subsequent pre-effective amendment: form of the variable annuity contract; form of application used with the foregoing variable annuity contract; and copy of distribution contract between registrant and the principal underwriter.

We understand that the registrant is responsible for the accuracy and adequacy of the disclosures in the filing and that staff comments or our changes to the disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing. In addition, the registrant may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the Federal securities laws of the United States.

Please direct all comments and questions regarding this filing to the undersigned. In advance, thank you for your assistance with this filing.

Sincerely,

/s/ Doug Hodgson

Doug Hodgson

Counsel, Registrant

711 High Street

Des Moines, IA 50392-0300

(515) 362-2384

Hodgson.Doug@principal.com