SecProbe.io

<DOCUMENT>
<TYPE>CORRESP
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>

                        SELECTIVE INSURANCE GROUP, INC.
                               40 Wantage Avenue
                             Branchville, NJ 07890

                                                              March 22, 2005

BY FACSIMILE AND EDGAR

Securities and Exchange Commission
Division of Corporation Finance
450 Fifth Street, N.W.
Washington, D.C.  20549
Attn:  Ms. Sonia Barros

              Re:  Selective Insurance Group, Inc.
                   Registration Statement on Form S-4 (File No. 333-123315)
                   --------------------------------------------------------

Ladies and Gentlemen:

         Selective Insurance Group, Inc. (the "Registrant"), the obligor under
its 7.25% Senior Notes due 2034 (CUSIP No. 816300AC1) (the "Old Notes"), is
registering an exchange offer (the "Exchange Offer") pursuant to a
Registration Statement on Form S-4 in reliance on the position of the staff of
the Securities and Exchange Commission (the "Staff") enunciated in Exxon
Capital Holdings Corporation (available April 13, 1988), Morgan Stanley & Co.
Incorporated (available June 5, 1991) and Shearman & Sterling (available July
2, 1993). The Registrant represents as follows:

         a. The Registrant has not entered into any arrangement or
understanding with any person to distribute the 7.25% Senior Notes due 2034 to
be received in the Exchange Offer (the "New Notes") and, to the best of the
Registrant's information and belief, each person participating in the Exchange
Offer is acquiring the New Notes in the ordinary course of its business and
has no arrangement or understanding with any person to participate in the
distribution of the New Notes to be received in the Exchange Offer.

         b. In this regard, the Registrant will make each person participating
in the Exchange Offer aware (through the Exchange Offer prospectus or
otherwise) that if such person is participating in the Exchange Offer for the
purpose of distributing the New Notes to be acquired in the Exchange Offer,
such person (i) cannot rely on the position of the Staff enunciated in Exxon
Capital Holdings Corporation (available April 13, 1988) or interpretive
letters to similar effect and (ii) must comply with registration and
prospectus delivery requirements of the Securities Act of 1933, as amended
(the "Securities Act"), in connection with any secondary resale transaction.

         c. The Registrant acknowledges that such a secondary resale
transaction by such person participating in the Exchange Offer for the purpose
of distributing the New Notes should be covered by an effective registration
statement containing the selling security holder information required by Item
507 of Regulation S-K under the Securities Act.

         d. The Registrant will make each person participating in the Exchange
Offer aware (through the Exchange Offer prospectus) that any broker-dealer who
holds Old Notes acquired for its own account as a result of market-making
activities or other trading activities, and who receives New Notes in exchange
for such Old Notes pursuant to the Exchange Offer, may be a statutory
underwriter and must deliver a prospectus meeting the requirements of the
Securities Act (as described in Shearman & Sterling (available July 2, 1993))
in connection with any resale of such New Notes.

         e. The Registrant will include in the transmittal letter or similar
documentation to be executed by an exchange offeree in order to participate in
the Exchange Offer the following additional provisions:

            (1)   If the exchange offeree is not a broker-dealer, an
                  acknowledgment that it is not engaged in, and does not
                  intend to engage in, a distribution of the New Notes.

            (2)   If the exchange offeree is a broker-dealer holding Old Notes
                  acquired for its own account as a result of market-making
                  activities or other trading activities, an acknowledgment
                  that it will deliver a prospectus meeting the requirements
                  of the Securities Act in connection with any resale of New
                  Notes received in respect of such Old Notes pursuant to the
                  Exchange Offer; and a statement to the effect that by so
                  acknowledging and by delivering a prospectus, such
                  broker-dealer will not be deemed to admit that it is an
                  "underwriter" within the meaning of the Securities Act.

                                       Very truly yours,

                                       SELECTIVE INSURANCE GROUP, INC.

                                       By: /s/ Michele N. Schumacher, Esq.
                                           -------------------------------
                                          Name:  Michele N. Schumacher, Esq.
                                          Title: Vice President, Corporate
                                                 Secretary & Corporate
                                                 Governance Officer

</TEXT>
</DOCUMENT>