October 9, 2014

Via EDGAR

Alberto Zapata

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

Principal Pivot Series Variable Annuity

File Numbers 333-197214 and 811-02091

Third Pre-Effective Amendment to the Registration Statement on Form N-4

Dear Mr. Zapata:

Enclosed is pre-effective amendment no. 3 to registration statement on Form N-4 for Principal Pivot Series Variable Annuity

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