SecProbe.io

September 24, 2012

Via E -mail
Mr. Robert J. Barish
Senior Vice President and Controller
Verizon Communications Inc.
140 West St.
New York, NY 10007

Re: Verizon Communications Inc.
 Form 10-K for the Fiscal Year Ended December 31, 2011
Filed February 24, 2012
File No. 1-08606

Dear Mr. Barish :

We have reviewed your filing an d have the following comment.  In our comment, we
may ask you to provide us with information so we may better understand your disclosure.

Please respond to this letter within ten business days by amending your filing, by
providing the requested information, or by advising us when you will provide the requested
response.   If you do not believe our comment a pplies to your facts and circumstances or do not
believe an amendment is appropriate, please tell us why in your response.

After reviewing any amendment to your filing and the information you provide in
response to this comment, we may have  additional comments.

Form 10 -K for the Fiscal Year Ended December 31, 2011

Risk Factors, page 15

Breached of network or information technology security, natural disasters or…, page 17

1. We note your response to comment 1 from our letter d ated August 27, 2012 in which
you state that you will revise your risk factor disclosure in your Form 10 -K based on
the facts and circumstances at the time.   We also note that in your response you
acknowledge that you have been subject, and will likely con tinue to be subject, to
attempts to breach the security of your networks and IT infrastructure through cyber
attack, malware, computer viruses and other means of unauthorized access.  It does
not appear that you have previously disclosed to your investors that this risk is one
that you are currently subject to and actively working to prevent.  Beginning with
your next Form 10 -Q, please confirm that you will disclose that you have been
subject, and will likely continue to be subject, to attempts to breach the security of

Mr. Robert J. Barish
Verizon Communications Inc.
September 24, 2012
Page 2

 your networks and IT infrastructure through cyber attack, malware, computer viruses
and other means of unauthorized access.

We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain  that the filing includes the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules require.   Since the company and its management are
in possession of all facts relating to a company’s disclosure, they are responsible for t he accuracy
and adequacy of the disclosures they have made.

 In responding to our comments, please provide  a written statement from the company
acknowledging that:

 the company is responsible for the adequacy and accuracy of the disclosure in the filing ;

 staff comments or changes to disclosure in response to staff comments do not foreclose
the Commission from taking any action with respect to the filing; and

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

You may contact Sharon Virga, Senior Staff Accountant , at 202-551-3385  or Terry
French, Accountant Branch Chief, at 202-551-3828  if you have questions regarding comments
on the fi nancial statements and related matters.  Please contact Kate Beukenkamp, Attorney -
Advisor, at 202-551-6971 or me at 202-551-3810  with any other questions.

Sincerely,

 /s/ Terry French for

Larry Spirgel
Assistant Director