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SEC Company Response from PLDT Inc. (PHI, PHTCF) (CIK 0000078150) (PHI) — Jan 9, 2007

PLDT Inc. (PHI, PHTCF) (CIK 0000078150)
Date: Jan. 9, 2007 · CIK: 0000078150 · Accession: 0000078150-07-000002

AI Filing Summary & Sentiment

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Document Type
Confidence
SEC Posture
Company Posture

Summary

Reasoning

Referenced dates: December 21, 2006

Date
December 31, 2005
Author
/s/ Ma. Lourdes C. Rausa-Chan
Form
CORRESP
Company
PLDT Inc. (PHI, PHTCF) (CIK 0000078150)

Letter

Via EDGAR (Correspondence) and Fax Office of Global Security Risk Division of Corporation Finance Securities and Exchange Commission United States of America Re: Philippine Long Distance Telephone Company Limited Annual Report on Form 20-F for the Fiscal Year ended December 31, 2005 Filed June 29, 2006 File No. 1- 03006

Dear Ms. Blye:

We refer to our letter, dated December 29, 2006, in which we acknowledged that Philippine Long Distance Telephone Company Limited (the “Company”) received on December 27, 2006 the comment letter from the staff dated December 21, 2006 relating to the Company’s Annual Report on Form 20-F for the fiscal year ended December 31, 2005 (the “Form 20-F”), and sought an extension for our response to January 15, 2007. The Company has determined that it will need more time than initially anticipated to collect and analyze the relevant data for its response, and now expects to be in a position to provide a response on or about February 9, 2007.

Very truly yours,
/s/ Ma. Lourdes C. Rausa-Chan

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CORRESP
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                                                                                    January
9, 2007

Via EDGAR (Correspondence) and Fax

Ms.
Cecilia D. Blye, Chief

Office of Global Security Risk

Division of Corporation Finance

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

United States of America

Re:       Philippine Long Distance
Telephone Company Limited

            Annual Report on Form
20-F for the Fiscal Year ended December 31, 2005

Filed June 29, 2006

File No. 1- 03006

Dear Ms. Blye:

We refer to our letter, dated December 29, 2006, in which
we acknowledged that Philippine Long Distance Telephone Company Limited (the
“Company”) received on December 27, 2006 the comment letter from the
staff dated December 21, 2006 relating to the Company’s Annual Report on Form
20-F for the fiscal year ended December 31, 2005 (the “Form 20-F”), and sought
an extension for our response to January 15, 2007.  The Company has determined
that it will need more time than initially anticipated to collect and analyze
the relevant data for its response, and now expects to be in a position to
provide a response on or about February 9, 2007.

Very truly yours,

/s/ Ma. Lourdes C. Rausa-Chan

MA. LOURDES C. RAUSA-CHAN

Senior Vice President

Corporate Affairs and Legal
Services Head and Corporate Secretary

cc:        Larry Spirgel

Terry French

Pradip Bhaumik

            (Securities and Exchange
Commission)

            Christopher H. Young

Ms. Anabelle L. Chua

June Cheryl C. Furigay

            (Philippine Long
Distance Telephone Company)

            John D. Young, Jr.

Michael G. DeSombre

Urs Fankhauser

(Sullivan & Cromwell LLP)