Request for Withdrawal of S-3 Registration – AXA Financial Inc.

Sun Jin Moon
Vice President and Counsel

(212) 314-2120

Fax: (212) 314-3953

[MONY LOGO]
LAW DEPARTMENT

September 11,
2009
VIA EDGAR
———

Securities and Exchange Commission
100 F Street, NE
Washington, D.C. 20549

Re: AXA Financial, Inc. – File No. 333-150631-01
MONY Life Insurance Company of America – File No. 333-150631

———————————————————-

Commissioners:

On behalf of MONY life Insurance Company of America and AXA
Financial,
Inc. (the “Registrants”), we hereby request that the above-referenced
Registration Statement filed on Form S-3 be withdrawn pursuant to Rule 477 under

the Securities Act of 1933, as amended.

The Registration Statement was initially filed with the Commission on

May 5, 2008 (Accession No. 0000089024-08-000301). The Registrants have
determined at this time not to pursue the offering of securities pursuant to

this Registration Statement. Furthermore, no securities have been sold under the

Registration Statement.

If you have any questions or comments concerning this request, please

call me at 212-314-2120.

Very truly yours,

/s/ Sun Jin Moon
——————
Sun Jin Moon

cc: Sony Oh, Esq.

MONY LIFE INSURANCE COMPANY OF AMERICA
1290 AVENUE OF THE AMERICAS, NEW YORK, NEW YORK 10104