SecProbe.io

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549

       DIVISION OF
CORPORATION FINANCE

Mail Stop 3720

April 8, 2008

Via U.S. Mail

Mr. Glen F. Post, III Chairman of the Board of Directors and  Chief Executive Officer CenturyTel, Inc. 100 CenturyTel Drive Monroe, Louisiana 71203
 RE: CenturyTel, Inc.
  Form 10-K for the fiscal year ended December 31, 2007
  Filed February 29, 2008   File No. 1-7784

Dear Mr. Post:
We have reviewed your filing and have the following comments.  If you disagree with a
comment, we will consider your explanation as to why it is inapplicable or a revision is unnecessary.  Please be as detailed as  necessary in your explanation.
  In some comments we have asked you to provide  us with additional information so we may
better understand your disclosure.  You should comp ly with the remaining comments in future
filings, as applicable.  Confirm in writing that you will do so and also explain to us how you intend
to comply.  Please do so within the time frame se t forth below.  Please u nderstand that after our
review of your responses, we may raise additional comments.

Form 10-K for the year ended December 31, 2007

Item 7. Management’s Discussion and Analysis of Financial Condition and Results of Operations
Overview
1. We note your disclosure throughout highlightin g several negative trends affecting your
voice and network access revenues.   Loss of access lines is antic ipated to continue in 2008.
In addition, excluding the non-recurring network access revenues attributed to your
settlement of a dispute w ith a carrier and the Madi son River Acquisition in 2007,

Mr. Glen F. Post, III
CenturyTel, Inc.
April 8, 2008 Page 2

management expects your network access revenues to  continue to decline.  In future filings,
discuss whether management is taking any specific steps to stem these negative trends.  If
so, explain how such steps are intended to reverse or counter the revenue declines.
 (1) SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES

Revenue Recognition
2. We note your policy of deferring revenues from in stallation activities and related costs, and
amortizing them over the estimated life of the customer relationship.  Describe for us, in detail, the nature of the installation related co sts and your basis in th e accounting literature
for capitalizing these costs.  Clarify whether you  only capitalize these costs to the extent of
deferred revenue and, if not, your basis for cap italizing excess costs.  Tell us how you
assess whether these costs are recoverable.
 (10) POSTRETIREMENT BENEFITS

3. Explain to us why you increased the assumed discount rate used when determining your postretirement benefit obligation from 5.75%  in 2006 to 6.50% in 2007. Similarly, explain
the increase in the discount ra te used for determining benefit cost, from 5.50% in 2006 to
5.75% in 2007.  Refer us to any reference rate s that you rely upon as  support for the 2007
rates. Confirm to us that your method for dete rmining the discount rates has not changed or
explain why and how it has changed.
 (11) DEFINED BENEFIT AND OTHER RETIREMENT PLANS

4. Explain to us why you increased the assumed discount rate when determining the pension plan benefit obligation from 5.8% in 2006 to 6.30% in 2007. Similarly explain the increase
in the discount rate used for determining benefit cost, from 5.50% in 2006 to 5.80% in 2007.  Refer us to any reference rates that you re ly upon as the basis for your discount rates.
Explain to us why these discount rates differ from the rate s used in calculating your
postretirement benefit obligations and costs.  Also, confirm to us that your method for determining the discount rates has not changed or explain why and how it has changed.  We
refer you to the guidance in EITF Topic No. D-36.

*    *    *    *

Please respond to these comments within 10 business days or tell us when you will provide
us with a response.  Please furn ish a letter that keys your resp onses to our comments and provides
any requested information.  Detailed letters greatly facilitate our review.  Please file  your letter over
EDGAR.  Please understand that we may have additional comments after reviewing your responses to our comments.

Mr. Glen F. Post, III
CenturyTel, Inc.
April 8, 2008
Page 3

 We urge all persons who are responsible for th e accuracy and adequacy of the disclosure in
the filings reviewed by the staff to be certain th at they have provided all information investors
require for an informed decision.  Since the comp any and its management are in possession of all
facts relating to a company’s disc losure, they are responsible for th e accuracy and adequacy of the
disclosures they have made.

 In connection with responding to our comment, please provide, in writing, a statement from
the company acknowledging that
• the company is responsible for the adequacy and accuracy of the disclo sure in the filings;

• staff comments or changes to disclosure in re sponse to staff comments do not foreclose the
Commission from taking any action with respect to the filings; and

• the company may not assert staff comments as a defense in any proceeding initiated by the
Commission or any person under the federal securities laws of the United States.

In addition, please be advised th at the Division of Enforcement has access to all information
you provide to the staff of the Division of Corpora tion Finance in our review of your filings or in
response to our commen ts on your filings.

You may contact Joseph M. Ke mpf, Senior Staff Accountant,  at (202) 551-3352 or Robert
Littlepage, Accounting Branch Chief, at ( 202) 551-3361, if you have questions regarding
comments on the financial statements and related ma tters.  Please call Paul Fischer, Staff Attorney,
at (202) 551-3415 or me, at (202) 551-3810, with any other questions.

 Sincerely,     Larry Spirgel  Assistant Director