SecProbe.io

<DOCUMENT>
<TYPE>CORRESP
<SEQUENCE>1
<FILENAME>corresp.txt
<DESCRIPTION>AMERICAN EXPRESS VUL IV/VUL IV-ESTATE SERIES-CORRESPONDENCE
<TEXT>
                                                        (logo)
                                                        AMERICAN
                                                         EXPRESS
                                                        (R)

                                                      IDS Life Insurance Company
                                                      50605 AXP Financial Center
                                                      Minneapolis, MN 55474

October 6, 2004

VIA EDGAR (Correspondence Filing)

Mark Cowan
Office of Insurance Products
Division of Investment Management
Securities and Exchange Commission
450 Fifth Street, N.W.  (Mail Stop 5-6)
Washington, D.C. 20549-1004

ATTN:           Document Control - Edgar

RE:             IDS Life Variable Life Separate Account ("Registrant")
                American Express (R) Variable Universal Life IV - Estate Series
                Post-Effective Amendment No. 13 ("Amendment No. 13")
                On Form N-6 (File No. 333-69777)
                Investment Company Act No. 811-4298

Dear Mr. Cowan:

This letter is in response to Staff's oral comments sent via voicemail on or
about October 6, 2004 to Amendment No. 13 for the above-referenced variable life
insurance product. Staff had no comments except the requirement to make the
following representation on behalf of the Registrant:

In connection with Amendment No. 13, IDS Life Insurance Company, (the "Company")
on behalf of the Registrant, hereby acknowledges the following:

         The disclosures in the filing are the responsibility of the Company and
         the Company is fully responsible for the adequacy or accuracy of the
         disclosures in this filing. The Company represents to the Commission
         that comments made by the Commission, or the staff acting pursuant to
         delegated authority, or changes to disclosure in response to staff
         comments in the filing reviewed by the staff, do not foreclosure the
         Commission from taking any action with respect to the filing, and the
         Company represents that it will not assert this action as a defense in
         any proceeding initiated by the Commission or any person, under the
         federal securities laws of the United States.

If you have any additional questions, please call Mary Ellyn Minenko at
612-671-3678 or Simone Pepper at 612-671-2847.

Sincerely,

/s/ Paul R. Johnston
----------------------
    Paul R. Johnston
    Assistant General Counsel and Secretary
    IDS Life Insurance Company

cc:      Mary Ellyn Minenko
         Simone Pepper

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