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CORRESP
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ALISON RYAN

AVP & Managing Assistant General
Counsel II

Phone: 949-219-3268

May 23, 2024

Yoon Choo

Senior Counsel

Office of Insurance Products

Division of Investment Management

U.S. Securities & Exchange Commission

100 F Street, NE

Washington, DC 20549-0506

    Re:
    Pacific Life Insurance Company

    Response to SEC comments for Initial Registration Statement on Form N-6

    File No. 333-275837

Dear Ms. Choo

On behalf of Pacific Life Insurance Company (“Pacific Life”
or the “Company”), we have set forth below responses to the Staff comments received on March 27 and March 28, 2024, in connection
with the above-referenced initial registration statement on Form N-6, file no. 333-275837 (the “Registration Statement”),
filed by the Company on December 1, 2023, under the Securities Act of 1933, as amended.

We have restated each of the Staff's comments below, and followed each comment
with the Company's response. This letter and a redlined prospectus reflecting the changes have been filed via a Correspondence filing on Edgar. Additionally, we will
provide the Staff with a courtesy copy of such filing.

All agreed-upon changes mentioned herein will appear in a pre-effective amendment
to the Registration Statement, which will be filed prior to the eventual effective date. The Company is currently targeting an effective
date of June 17, 2024. Accordingly, we kindly request any additional Staff comments by June 7, 2024.

GENERAL

PROSPECTUS

Cover Page

 1. Per comment #4 in the March 1 letter, please also add a reference to “fixed”
and add reference to who offers the Fixed and Indexed accounts. Delete the first instance of “issued by”.

Response:
Revisions have been made to address the Staff’s comment.

 2. At the bottom of the cover page, given the importance of this language, please consider placing “Withdrawals
not allowed” as a separate paragraph.

Response:
Revisions have been made to address the Staff’s comment.

Special
Terms

 3. In the definitions of the 1-Year Indexed Account and 1-Year High Par Volatility
Control

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    Indexed Account, please add a reference to the guaranteed adjustment factor.

Response:
Revisions have been made to address the Staff’s comment.

 4. Please revise the second sentence of the definition of “Index”:

 a. Please revise the second sentence of the definition to note the impact
of indexes not reflecting reinvestment of dividends, i.e. it reduces returns.

Response:
Revisions have been made to address the Staff’s comment.

 b. Also, please revise to address the impact of fees and costs on the BlackRock
iBLD Endura index. For example, the Company could state that references to each index excludes dividend, which reduces index returns.
The index component of the BlackRock iBLD Endura index are ETFs which deduct fees and costs when calculating ETF Performance which also
reduce the index return.

Response:
Revisions have been made to address the Staff’s comment.

 5. Please revise the definition of Indexed Account. Please
revise the second sentence to state that interest credited at Segment Maturity based in part, on any positive change, in the index for
a Segment Term, adjusted by an application of the Participation Rate, Growth Cap, if applicable, Segment Guaranteed Minimum Interest Rate,
and the Segment Adjustment Factor. In each place where these factors are listed, please consistently list the factors in the order they
are applied to arrive at interest credited.

Response:
Revisions have been made to address the Staff’s comment. We believe it would be repetitive to also add the factors.

 6. Please reconcile the last sentence of the Indexed Account definition
with disclosure later in the prospectus, that the 2nd index account is the 1-Year High Par Volatility Control Indexed Account, please
conform all references in the Prospectus to the correct name. Whichever term is correct, use it consistently.

Response:
Revisions have been made to address the Staff’s comment.

 7. The
                                            discussion of the Segment Guaranteed Interest and the calculation of the Segment Indexed
                                            Interest Rate in the definitions section and in the discussion later in the prospectus are
                                            very difficult to follow. While the definition of Segment Guaranteed Interest states that
                                            the Company credits interest DAILY during
                                            the Segment Term, the definition of Minimum Segment Guaranteed Interest Rate states that
                                            it is the minimum annual rate that is added AT SEGMENT
                                            MATURITY. Furthermore, the formula for Segment Indexed Interest Rate does not account
                                            for any Segment Guaranteed Interest applied during the Segment Term. It also subtracts the
                                            Minimum Segment Guaranteed Interest Rate from the return based on the Index Growth Rate adjusted
                                            by the Participation Rate and the Growth Cap. Finally, no mention is made of the Segment
                                            Adjustment Factor in calculating the Segment Indexed Interest Rate, even though the prospectus
                                            states that the Segment Adjustment Factor can "increase, decrease, or have no effect
                                            on the amount of interest credited at the end of a Segment Term." Please revise the
                                            definitions and the disclosure around Segment Indexed

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     Interest
(here and under Indexed Fixed Options) so that investors have a clear understanding of how this amount is calculated, including how each
adjustment factor affects the calculation. In this regard, consider whether defined terms can be consolidated or revised to better distinguish
terms that are very similar (e.g., Minimum Segment Guaranteed Interest Rate and Segment Guaranteed Interest).

Response:
Revisions have been made to address the Staff’s comment.

 8. A Segment can also be created from amounts allocated from a prior Segment
of an Indexed Account as long as the maturing Segment has a value greater than zero. Please revise this and similar statements throughout
the prospectus. Please confirm whether it has to be from the same strategy, or can it be from a different strategy?

Response:
Revisions have been made to the term Segment Start Dates to address the Staff’s comments.

The
Segment Maturity Value is not required to be reallocated to the same Indexed Account that is maturing. The Policy Owner's Segment Maturity
reallocation instructions, which can be changed at any time, dictate where Segment Maturity Value will be reallocated.

 9. Please revise to briefly explain how the “Segment Adjustment Factor”
is used. Please disclose that the factor is subject to change from Segment Term to Segment Term.

Response:
Revisions have been made to address the Staff’s comment.

 10. Please supplementally explain how the term Segment Guaranteed Interest
functions differently from Minimum Segment Guaranteed Interest Rate.

Response:
The Minimum Segment Guaranteed Interest Rate is the minimum annual rate that is issued in the calculation of the Segment Guaranteed
Interest.

 11. The definition of “Segment Indexed Interest” suggests that
this is the final interest amount that may be credited at Segment Maturity. However, the discussion of Indexed Fixed Options on page 69
states that the Segment Indexed Interest is multiplied by the Segment Adjustment Factor to arrive at the "Total Interest Credited."
For ease of investor understanding:

 a. Please delete the defined term “Total Interest Credited.”

Response:
Revisions have been made to address the Staff’s comment.

 b. Please revise the definition of Segment Indexed Interest to state that
it is the interest, if any, that will be credited to a Segment of an Indexed Account at Segment Maturity by multiplying the Segment Indexed
Interest Rate by the average of all Segment monthly balances over the entire Segment Term; and add the Segment Adjustment Factor to the
calculation of Segment Indexed Interest Rate.

Response:
Revisions have been made to the definition of Segment Indexed Interest. The Segment Adjustment Factor cannot be added to the calculation
of the Segment Indexed

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Interest Rate. The rate should not be impacted by the Segment Adjustment Factor, which follows the Policy's defined
term.

 12. Please revise “Segment Indexed Interest Rate” to explain that
the Segment Indexed Interest Rate is applied at Segment Maturity based, in part, on the indexed growth rate adjusted for the various adjustment
factors. Please disclose each factor and the order of their application to arrive at this rate. In this connection, please add the Segment
Adjustment Factor as the factor used in arriving at this rate or supplementally explain why it would not appropriate to do so.

Response:
Per comment #11 in the March 1 letter, revisions have been made to address the Staff’s comment. The definition of Segment
Indexed Interest has been revised to address concerns.

 13. Please add reference to the Segment Adjustment Factor in the discussion
of the 1-Year Indexed Account and 1-Year High Par Volatility Control Indexed Account.

Response:
Revisions have been made to address the Staff’s comment.

 14. Please revise the definition of “Segment Value” to make clear
that the Segment Indexed Interest is applied only on the Segment Maturity date, and that Segment Value would equal a + b – c on
all other days. This may be broken out into two separate formulas.

Response:
Revisions have been made to address the Staff’s comment.

Important Information You Should Consider About the
Contract

Risks

 15. Please add “and any prior earnings” to the end of the Risk
of Loss sentence and later in the “Risk of Loss” subsection of Principal Risks of Investing in the Policy.

Response:
Revisions have been made to address the Staff’s comment.

Restrictions

 16. Please address the following comments to ─Investments:

 a. Add “, and Indexed Fixed Options,” in the third to last sentence
of paragraph 1.

Response:
Revisions have been made to address the Staff’s comment.

 b. Please briefly disclose the transfer restrictions applicable to the Fixed
Option.

Response:
Revisions have been made to address the Staff’s comment.

 c. Please add a reference to Variable Investment Options (or Fund Options)
at the end of the last sentence of this section.

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Response:
Revisions have been made to address the Staff’s comment.

 d. Since there are no rider-based investment restrictions, please remove
cross reference to “Appendix: Funds Available Under the Policy” in the Optional Benefits row.

Response:
Revisions have been made to address the Staff’s comment.

Fee Tables

 17. Please make underwriting methods statement more prominent.

Response:
Revisions have been made to address the Staff’s comment.

 18. Related to Footnote 4 and the current Coverage charge:

 a. Please add a statement before the sentence that starts “For the
current Coverage charge…”, to the effect - "If there is a reduction in the Face Amount of a Basic Life Coverage Layer,
including decreases for any withdrawals, the Coverage charge for the effected Basic Life Coverage Layer will not change.”

Response:
Revisions have been made to address the Staff’s comment.

 b. Please provide more information about the current Coverage charge under
the Coverage charge discussion later in the prospectus.

Response:
Revisions have been made to address the Staff’s comment.

Principal Risks of Investing in the Policy

 19. In the fifth sentence under ─Unsuitable as Short-Term Savings
Vehicle, please add “and tax penalties” to the end of the sentence.

Response:
Revisions have been made to address the Staff’s comment.

 20. Under ─Risks Associated with Indexed Fixed Options, please
supplementally confirm that the Minimum Segment Guaranteed Interest Rate is not factored in the Company’s option strategy.

Response:
The Minimum Segment Guaranteed Interest Rate is 0 and is not factored in the Company’s option strategy.
If at any point the Minimum Segment Guaranteed Interest Rate were to be greater than 0, the Company would modify the prospectus accordingly
to address the Segment Guaranteed Interest Rate.

 21. Under ─Risks Associated with Fixed Options, please add a reference
to the Fixed LT Account in the paragraph.

Response:
Revisions have been made to address the Staff’s comment.

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Death Benefits

 22. Under ─Basic Face Amount, please add parenthesis around the
new disclosure and move it to immediately follow the second sentence of the first paragraph of the subsection. In addition, after “associated
Coverage charge” please add “or Surrender Charge”.

Response:
Revisions have been made to address the Staff’s comment.

Optional Riders and Benefits

 23. In the description of the Premier Chronic Illness Rider, please add a
statement to the effect that this rider is not available if the investor’s Policy was issued with the Premier Living Benefits Rider
2.

Response:
Revisions have been made to address the Staff’s comment.

Your Investment Options

Variable Options

 24. In the first paragraph of the section please consider the following:

 a. Please consider making the disclosure that starts with “We may add
or remove…” more prominent.

Response:
Revisions have been made to address the Staff’s comment.

 b. Please disclose which Variable Investment Option will always be available.

Response:
 Respectfully, it is impractical for us to commit to a specific Variable Investment Option always being available. For example,
Pacific Life could commit to a specific Fund, which could then be merged into another Fund.

 c. Just before the sentence “Investors should discuss with their financial
professional…”, please add a sentence to the effect: “If, in the future, an investor is not satisfied with the Variable
Investment Options, they may choose to surrender their Policy, but they may be subject to Surrender Charges, taxes, and tax penalties.
If they purchase another investment vehicle, it may have different feature, fees, and risks than the Policy.”

Response:
 Revisions have been made to address the Staff’s comment.

 d. Here and elsewhere, please provide a specific landing page website.

Response:
 Respectfully, we are unable to implement this comment at this time. Currently, this product will be sold through an exclusive
distributor. We also note that this product will not rely on Rule 498A of the Investment Company Act of 1940 (Summary Prospectus

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Rule)
with regard to issuing an Initial Summary Prospectus and Updating Summary Prospectus. We note that there is no requirement to post the
underlying funds’ prospectus and related documents on the Pacific Life website. We have added that a Policy Owner may contact their
financial professional or call 800-347-7787.

Indexed Fixed Options

 25. Please add a sentence disclosing the related Index for each Indexed Account
in the paragraph before the box summary.

Response:
Revisions have been made to address the Staff’s comment.

 26. To the extent not disclosed, in an appropriate location in the prospectus,
add a description of each Index, how it is constituted and the intended material risk.

Response:
Revisions have been made to address the Staff’s comment.

 27. Please revise the summary comparing the Indexed Fixed Options as follows:

 a. Please delete the “Maximum Indexed Fixed Option Charge” line
item, it does not appear anywhere else in the prospectus.

Response:
Revisions have been made to address the Staff’s comment.

 b. If the Segment Adjustment Factor is applied before determining whether
the minimu