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SEC Comment Letter for PLDT Inc. (PHI, PHTCF) (CIK 0000078150) (PHI) — Dec 15, 2014

PLDT Inc. (PHI, PHTCF) (CIK 0000078150)
Date: Dec. 15, 2014 · CIK: 0000078150 · Accession: 0000000000-14-064557

AI Filing Summary & Sentiment

Sentiment
Urgency
Document Type
Confidence
SEC Posture
Company Posture

Summary

Reasoning

Date
December 12, 2014
Author
/s/ Kathleen Kreb s, for
Form
UPLOAD
Company
PLDT Inc. (PHI, PHTCF) (CIK 0000078150)

Letter

December 12, 2014 Via E -mail Napoleon L. Nazareno President and Chief Executive Officer Philippine Long Distance Telephone Company Ramon Cojuangco Building Makati Avenue Makati City, Philippines

Re: Philippine Long Distance Telephone Company Form 20-F Filed April 2, 2014 File No. 001 -03006

Dear Mr. Nazareno :

We have completed our review of your filing . We remind you that our comments or changes to disclosure in response to our comments do not foreclose the Commission from taking any action with respect to the company or the filing 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. We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing include s the information the Securities Excha nge Act of 1934 and all applicable rules require.

Sincerely,
/s/ Kathleen Kreb s, for

Show Raw Text
December 12, 2014

Via E -mail
Napoleon L. Nazareno
President and Chief Executive Officer
Philippine Long Distance Telephone Company
Ramon Cojuangco Building
Makati Avenue
Makati City, Philippines

Re: Philippine Long Distance Telephone Company
 Form 20-F
Filed April 2, 2014
File No. 001 -03006

Dear Mr. Nazareno :

We have completed our review of your filing .  We remind you that our comments or
changes to disclosure in response to our comments do not foreclose the Commission from taking
any action with respect to the company or the filing  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.  We urge all persons who are responsible for the
accuracy and adequacy of the disclosure in the filing  to be certain that the filing  include s the
information the Securities Excha nge Act of 1934 and all applicable rules require.

Sincerely,

 /s/ Kathleen Kreb s, for

 Larry Spirgel
Assistant Director

cc: Via E -mail
Ma. Lourdes C. Rausa -Chan
Senior Vice President and Corporate Secretary
Philippine Long Distance Telephone Company

Michael G. DeSombre
Sullivan  & Cromwell  LLP