April 30, 2008

VIA EDGAR

Securities and Exchange Commission
450 Fifth Street, NW
Washington, DC 20549

RE Principal Life Insurance Company
Separate Account B
Flexible Variable Annuity Contract
Registration Statement on Form N-4
File No. 33-74232

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/ Sarah J. Pitts
Counsel
515-248-3259
pitts.sarah@principal.com