SecProbe.io

<DOCUMENT>
<TYPE>CORRESP
<SEQUENCE>1
<FILENAME>idsl-corresp.txt
<DESCRIPTION>IDS LIFE VARIABLE LIFE SEPARATE ACCOUNT
<TEXT>
December 10, 2004

VIA EDGAR and FACSIMILE (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) Succession Select Variable Life Insurance
                  Post-Effective Amendment No. 12
                  On From N-6 (File No. 33-62457)
                  Investment Company Act No. 811-4298

                  American Express(R) Variable Universal Life IV/American
                  Express (R) Variable Universal Life IV - Estate Series and
                  American Express (R) Variable Universal Life III
                  Post-Effective Amendment No. 15
                  On Form N-6 (File No. 333-69777)
                  Investment Company Act No. 811-4298

                  American Express (R) Variable Universal Life Insurance
                  Post-Effective Amendment Nos. 27 and 28
                  On Form N-6 (File No. 33-11165)
                  Investment Company Act No. 811-4298

                  American Express (R) Single Premium Variable Life
                  Post-Effective Amendment No. 4
                  On Form N-6 (File No. 333-83456)
                  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 December 10, 2004 for the Registrant and Post-Effective Amendments
(collectively, the "Amendments") listed above. Staff had no comments except the
requirement to make the following representation on behalf of the Registrant:

In connection with the Amendments, 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/  Heather M. Somers
-----------------------
     Heather M. Somers
     Assistant General Counsel
     IDS Life Insurance Company

Cc:      Mary Ellyn Minenko
         Simone Pepper

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