SEC Comment Letter for VERIZON COMMUNICATIONS INC (VZ) (CIK 0000732712) (VZ) — Dec 5, 2013
VERIZON COMMUNICATIONS INC (VZ) (CIK 0000732712)
Date: Dec. 5, 2013 · CIK: 0000732712 · Accession: 0000000000-13-066350
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File numbers found in text: 333-191628
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December 5 , 2013
Via E -mail
Randal S. Milch
Executive Vice President – Public Policy and General Counsel
Verizon Communications Inc.
140 West Street
New York, NY 10007
Re: Verizon Communications Inc.
Amendment No. 1 to Registration Statement on Form S -4
Filed November 12, 2013
Response dated November 29, 2013
File No. 333-191628
Dear Mr. Milch:
We have reviewed your response and have the following comment .
Please respond to this letter by amending your registration statement or providing the
requested information. If you do not believe our comment applies to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in yo ur
response.
After reviewing any amendment to your registration statement and the information you
provide in response to this comment , we may have additional comments.
General
1. We note your response to comment 7 from our letter dated November 22 , 2013. Please
confirm your intent to file a copy of the tax opinion provided supplementally to the staff
as an exhibit to your registration statement pursuant to Item 601(b)(8) of Regulation S -K.
Randal S. Milch
Verizon Communications Inc.
December 5 , 2013
Page 2
We urge all persons who are responsible for the accuracy and ade quacy of the disclosure
in the filing to be certain that the filing includes the information the Securities Act of 1933 and
all applicable Securities Act rules require. Since the company and its management are in
possession of all facts relating to a comp any’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.
Please contact Brandon Hill, Attorney Advisor, at (202) 551 -3268 or me at (202) 551 -
3810 with any other questions.
Sincerely,
Larry Spirgel
Assistant Director