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                    Allianz Life Insurance Company of North America

                    John Hite

                    Senior Counsel, Associate General Counsel

                    Corporate Legal

                    5701 Golden Hills Drive

                    Minneapolis, MN  55416-1297

                    Telephone: 763-765-7494

                    John.Hite@allianzlife.com

                    www.allianzlife.com

          CORRESPONDENCE FILING

          March 19, 2024

          Mr. Mark Cowan, Senior Counsel

          Securities and Exchange Commission

          Division of Investment Management, Disclosure Review Office

          100 F Street NE

          Washington, DC 20549-8626

          Re: Post-Effective Amendment No. 4 to the Form S-1 Registration Statement, Submitted December 20,
              2023, File No. 333-268820 (Allianz Index Advantage+ Income Variable Annuity)

          Mr. Cowan:

          We received comments from you on February 8, 2024, with respect to Registrant’s above referenced Post-Effective
            Amendment No. 4 to the Form S-1 Registration Statement, filed on December 20, 2023. This correspondence responds to your comments. We will make conforming changes to the prospectus in both the Form S-1 and Form N-4 Registration Statements, and
            to the Registration Statements for other products where applicable.

          February 8, 2024 Prospectus Comments

          I. PROSPECTUS

          Cover Page

                    1.

                    The cover page discloses the maximum potential negative Performance Credit related to 10%, 20%, and 30% Buffers. Please confirm that the
                      Index Options associated with those listed Buffers reflect the Index Options available on the Contract and that they will always be offered.

                Response:

                  Allianz Life Insurance Company of North America (the “Company”) confirms that the listed Buffers on the cover page reflect those Index Options currently available. Additionally, the
                    Company confirms that an Index Option cannot be removed from the Contract, unless it is simultaneously substituted by a new Index in accordance with the disclosures in the “Risks Associated with Substitution of an Index” section.

                    2.

                    Please add information relating to the minimum Participation Rates, Caps, and Trigger Rates available with Crediting Methods to the cover
                      page.

                Response:

                  In accordance with the Staff’s comment, the following sentences have been added to the cover page: “The Index Protection Strategy with Trigger provides a
                      0.50% minimum Trigger Rate. The Index Protection Strategy with Cap provides a 0.50% minimum Cap. The Index Dual Precision Strategy and Index Precision Strategy

          provide a 3% minimum Trigger Rate. The Index Guard Strategy provides a 3% minimum
              Cap. The Index Performance Strategy 1-year Term Index Options provide a 3% minimum Cap. The Index Performance Strategy 3-year Term Index Options provide a 5% minimum Cap. Lastly, the Index Performance Strategy 6-year Term Index Options
              provide a 10% minimum Cap. Both the Index Performance Strategy 3-year and 6-year Index Options provide a 100% minimum Participation Rate.”

          Glossary

                    3.

                    Within various locations throughout the prospectus, terminology is applied inconsistently between variable
                        investment option, underlying mutual fund, and variable subaccount. Please revise the associated language to consistently apply the terminology throughout the prospectus. Additionally, please ensure that disclosure is clear that
                        investment in the AZL Government Money Market Fund is an investment in the variable subaccount and not a direct investment in the fund.

                Response:

                  The Company has revised the identified language consistent with the Staff’s comment. The Company will provide a revised prospectus under separate cover detailing the revisions made in
                    accordance with the comment.

                    4.

                    Please add clarifying language throughout the prospectus indicating that the availability of certain Crediting
                        Methods and/or Index Options varies based on Issue Date. For example, consider adding language to the Glossary indicating that the availability of Buffers varies by Issue Date and that additional information may be located through a
                        cross-reference.

                Response:

                  The Company has added the following sentence to the definition of Buffer: “There are restrictions on the availability of the Buffers as discussed in
                      “Overview of the Contract – What Are the Phases of the Contract?” The Company has added a similar sentence to the definitions of Index Dual Precision Strategy and Index Performance Strategy.

                    5.

                    Definition of Contract Value: In the last sentence, please include a reference that the Contract Value includes any Daily
                      Adjustment. For example, “The Cash Value reflects all Contract fees and expenses we would apply on surrender (including any withdrawal charges and Daily Adjustment).”

                Response:

                  The Company has revised the identified language to state “The Cash Value reflects all Contract fees and expenses we would apply on surrender (including any
                      withdrawal charge), as well as any applicable Daily Adjustment.” The Company respectfully declines to state that the Daily Adjustment is an included ‘fee’ as the Daily Adjustment can be both positive and negative.

                    6.

                    Definition of Index Dual Precision Strategy: This definition currently includes disclosure explaining market environments when the Crediting
                      Method may perform best, as well as disclosure comparing the Crediting Method to other available options. Please consider whether this disclosure can either be removed or relocated within the prospectus.

                Response:

                  The Company has removed the identified language consistent with the Staff’s comment. The definition of Index Dual Precision Strategy has been revised to state, “one of
                    the Crediting Methods described in section 4, Valuing Your Contract. The

            2

          Index Dual Precision Strategy calculates Performance Credits based on Index
              Returns subject to a Trigger Rate and 10%, 20%, or 30% Buffer. This Crediting Method provides a positive Performance Credit for negative market movements when the loss is less than or equal to the applicable 10%, 20%, or 30% Buffer. You can
              receive negative Performance Credits under this Crediting Method, which means you can lose principal and previous earnings. Significant losses beyond the 10%, 20%, or 30% Buffer for the Index Dual Precision Strategy can result in substantial
              loss of principal and previous earnings. There are restrictions on the availability of the Buffers as discussed in “Overview of the Contract – What Are the Phases of the Contract?"

                    7.

                    Definition of Index Performance Strategy: Similar to the preceding comment, please consider whether the disclosure included within this
                      definition explaining the market environment when the Crediting Method may perform best, as well as disclosure comparing the Crediting Method to other available options, can be removed or relocated within the prospectus.

                Response:

                  In accordance with the Staff’s comment, the Company has removed the following sentences: “The Index Performance Strategy is more sensitive to large negative
                      market movements because small or moderate negative market movements are absorbed by the 10%, 20%, or 30% Buffer. In a period of extreme negative market performance, the risk of loss is greater with the Index Performance Strategy than
                      with the Index Guard Strategy.” Additional revisions have been made to the definitions of the Index Guard Strategy, Index Precision Strategy, Index Protection Strategy with Cap, and Index Protection Strategy with Trigger to remove
                      similar disclosure language.

                    8.

                    Definition of Participation Rate: Please include language indicating that the Participation Rate is applied
                        over the course of a Term.

                Response:

                  The Company has added clarifying language stating the Participation Rate is applied to any positive Index Return “over the course of a Term in calculating the Performance
                    Credit on the Term End Date.”

          Overview of the Contract – What Are the Phases of the Contract?

                    9.

                    Consider modifying the table of currently available Crediting Methods to further clarify the availability of
                        the Index Dual Precision Strategy and Index Performance Strategy Buffers based on Issue Date.

                Response:

                  The identified table has been modified in accordance with the Staff’s comments. For the Index Dual Precision Strategy, clarifying language has been added to indicate the
                    following:

                    •

                    For Contracts issued from May 1, 2023 to November 13, 2023 the Index Dual Precision Strategy is not available.

                    •

                    For Contracts issued from November 14, 2023 to April 30, 2024, only the 10% Buffer is available.

                    •

                    For Contracts issued since May 1, 2024, the 10%, 20%, and 30% Buffers are available.

            3

          For the Index Performance Strategy 1-year Term Index Options, clarifying language has been added to indicate the
            following:

                    •

                    For Contracts issued from May 1, 2023 to November 13, 2023, only the 10% Buffer is available.

                    •

                    For Contracts issued since November 14, 2023, the 10%, 20%, and 30% Buffers are available.

          Lastly, for the Index Performance Strategy 6-year Term Index Options, clarifying language has been added to indicate
            the following:

                    •

                    For Contracts issued from May 1, 2023 to November 13, 2023, only the 10% Buffer is available.

                    •

                    For Contracts issued since November 14, 2023, the 10% and 20% Buffers are available.

                    10.

                    Within the bullet describing the accumulation phase, there is reference to additional purchase payments being
                        subject to limitations. Please either specify those limitations or include a cross reference as to where an investor could find this information.

                Response:

                  The Company has added the following sentence to the end of the identified paragraph: “For more information regarding additional Purchase Payment limitations, please see
                    section 3, Purchasing the Contract – Purchase Requirements.”

          Risk Factors – Income Benefit Risks

                    11.

                    In the Income Benefit Risks section, please include disclosure indicating that a negative Daily Adjustment may
                        adversely affect the Index Protection Strategy with Trigger and Index Protection Strategy with Cap.

                Response:

                  The Company respectfully declines to adopt the Staff’s comment as the Daily Adjustment for the Index Protection Strategy with Trigger and Index Protection Strategy with
                    Cap cannot be negative.

          Valuing Your Contract

                    12.

                    Please include clarifying language within the “Variable Account Value increases when...” table indicating that
                        the Variable Account Value increases when Purchase Payments are allocated to the AZL Government Money Market Fund subaccount before being transferred to an investor’s selected Index Option.

                Response:

                  The Company has revised the identified language to state, “Variable Account Value increases when we hold assets in the Variable Option on an interim basis before
                    transferring them to your selected Index Option(s), or due to a Contract Value increase associated with the death of a Determining Life, or there is positive Fund performance.”

                    13.

                    Similar to the preceding comment, on page 44 of the prospectus, please include clarifying language indicating
                        when the number of subaccount accumulation units increases.

            4

                Response:

                  The Company has revised the identified language to state, “...the number of subaccount accumulation units increases when we hold assets in the Variable Option on an
                    interim basis before transferring them to your selected Index Option(s), or due to a Contract Value increase associated with the death of a Determining Life.”

          How the Crediting Methods Work

                    14.

                    Please include clarifying language indicating the availability of Crediting Methods and/or Buffers varies based
                        on Issue Date.

                Response:

                  The Company has added the following sentence to the end of the description of the Index Dual Precision Strategy found on page 43 of the prospectus and the Index
                    Performance Strategy found on page 44: “There are restrictions on the availability of the Buffers as discussed in ‘Overview of the Contract – What Are the Phases of the Contract?’”

          Access To Your Money

                    15.

                    At the bottom of page 67, the Staff noted that certain disclosure language has been removed. Please confirm
                        that the removal of this language is intentional.

                Response:

                  The Company confirms that the removal of this disclosure was intentional. The Company is of the opinion that the previously included language is repetitive
                      in light of the definition of Cash Value, which explains the deductions taken upon withdrawal. As a result, the Company views the identified language as unnecessary and has removed it for purposes of prospectus simplicity.

          Benefits Available Under the Contract

                    16.

                    In the Income Benefit row of the Benefits Table, please add a bullet indicating that the Income Benefit is
                        subject to the Daily Adjustment.

                Response:

                  The Company has added the following bullet to the Income Benefit Row: “If you have Contract Value in an Index Option for which the Income Benefit Date is not a Term End
                    Date, we will execute a Performance Lock for that Index Option if it is not locked and then immediately calculate and begin your Income Payments, and in such case the Index Option Value will be subject to the Daily Adjustment.”

          Death Benefit

                    17.

                    On page 89, the Staff noted that the following disclosure was removed: “However, if before the next Index
                        Anniversary we receive a Valid Claim and death benefit pa