VIA EDGAR
April 27, 2011
Securities and Exchange Commission
450 Fifth Street, NW
Washington, DC 20549
RE:	Principal Life Insurance Company
	Separate Account B
	Principal Investment Plus Variable Annuity
	Registration Statement on Form N-4
	File No. 333-116220

I am Counsel for the above-referenced Registrant, and have reviewed the attached post- 

effective amendment which is being filed pursuant to Rule 485(b) under the Securities 

Act of 1933. I hereby represent that the amendment does not contain disclosures which 

would render it ineligible to become effective pursuant to Rule 485(b). 

Sincerely, 

/s/ Jeffrey M. Pierick
Counsel
711 High Street
Des Moines, Iowa 503092-0300
(515) 362-2384 (office)
(866) 496-6527 (facsimile)
pierick.jeff@principal.com

JMP/kcr