SecProbe.io

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Mail Stop 0309	March 21, 2005

Michael H. Lanza, Esq.
Senior Vice President and General Counsel
Selective Insurance Group, Inc.
40 Wantage Avenue
Branchville, NJ 07890

Re:	Selective Insurance Group, Inc.
Registration Statement on Form S-4, filed March 14, 2005
File No. 333-123315

Dear Mr. Lanza:

      We have limited our review of the above referenced filing to
only the matters addressed herein.  Please understand that the
purpose of our review process is to assist you in your compliance
with the applicable disclosure requirements and to enhance the
overall disclosure in your filing.  We look forward to working
with
you in these respects.  We welcome any questions you may have
about
our comments or on any other aspect of our review.  Feel free to
call
us at the telephone numbers listed at the end of this letter.
1. We note that you are registering the new notes in reliance on
the
staff`s position enunciated in Exxon Capital Holdings Corporation,
SEC No-Action Letter (May 13, 1988); Morgan Stanley  & Co.
Incorporated, SEC No-Action Letter (June 5, 1991); and Sherman and
Sterling, SEC No-Action Letter (July 2, 1993). Accordingly, please
provide a supplemental letter to the staff (i) stating that you
are
registering the exchange offer in reliance on the staff`s position
contained in these no-action letters, and (ii) including the
statements and representations substantially in the form set forth
in
the Morgan Stanley and Sherman & Sterling no-action letters.

	We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings reviewed by the staff to
be
certain that they have provided all information investors require
for
an informed decision.  Since the company and its management are in
possession of all facts relating to a company`s disclosure, they
are
responsible for the accuracy and adequacy of the disclosures they
have made.

	Notwithstanding our comments, in the event the company
requests
acceleration of the effective date of the pending registration
statement, it should furnish a letter, at the time of such
request,
acknowledging that

* should the Commission or the staff, acting pursuant to delegated
authority, declare the filing effective, it does not foreclose the
Commission from taking any action with respect to the filing;
* the action of the Commission or the staff, acting pursuant to
delegated authority, in declaring the filing effective, does not
relieve the company from its full responsibility for the adequacy
and
accuracy of the disclosure in the filing; and
* the company may not assert this action as defense in any
proceeding
initiated by the Commission or any person under the federal
securities laws of the United States.

	In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in connection with our review of
your
filing or in response to our comments on your filing.

      We direct your attention to Rules 460 and 461 regarding
requesting acceleration of a registration statement.  Please allow
adequate time after the filing of any amendment for further review
before submitting a request for acceleration.  Please provide this
request at least two business days in advance of the requested
effective date.

      Please contact Sonia Barros at (202) 824-5304 with any other
questions.

								Sincerely,

								Jeffrey P. Riedler
								Assistant Director

cc:	Richard B. Aftanas, Esq.
      Skadden, Arps, Slate, Meagher & Flom LLP
      Four Times Square
      New York, NY 10036-6522

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Michael H. Lanza, Esq.
March 21, 2005
Page 1

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