SecProbe.io

Mail Stop 3720

August 26, 2015

Mr. Anthony T. Skiadas
Senior Vice President and Controller
Verizon Communications Inc.
1095 Avenue of the Americas
New York, New York  10036

Re: Verizon Communications Inc.
 Form 10 -K for Fiscal Year Ended December 31, 2014
Filed February 23, 2015
  File No. 1-08606

Dear Mr. Skiadas :

We have limited our review  of your filing  to the financial statements and related
disclosures and have the following comment.  In our comment, we ask you to provide us with
information so we may better understand your disclosure.

Please respond to this  comment within ten business days by providing the requested
information or advise u s as soon as possible when you will respond.  If you do not believe our
comment appl ies to your facts and circumstances, please tell us why in your response.

After reviewing your response to th is comment, we may have additional comments.

Form 10 -K for the fiscal year ended December 31, 2014

Exhibit 13

Note 14.  Segment Information

You disclose that you have operations in two reportable segments, Wireless and Wireline.
We note on page 8 that you organize your Wireline service and product  offerings by the primary
customers targeted.  In addition we note the remarks in your earnings calls of the impact on
operating results of the FiOS platform.  To help us understand how you applied the guidance in
FASB ASC 280 in identifying your operating  segments, please provide us with the following
information:

Mr. Anthony T. Skiadas
Verizon Communications Inc.
August 26, 2015
Page 2

 Provide your organization chart which identifies the positions, roles, or functions that
report directly to your chief operating decision maker (“CODM”) and senior management
team;
 Tell us the title and describe the role of your CODM and each of the individuals who
report to the CODM;
 Identify for us each of the operating segments you have determined in accordance with
FASB ASC 280;
 Identify and describe the role of each of your segment mana gers;
 Tell us how often the CODM meets with his/her direct reports, the financial information
the CODM reviews to prepare for those meetings, the financial information discussed in
those meetings, and who attends those meetings;
 Describe the information regularly provided to the CODM and tell us how frequently it is
prepared;
 Describe the information regularly provided to the Board of Directors and tell us how
frequently it is prepared;
 Describe the information about Wireline’s product and service offer ings that are provided
to the CODM, tell us whether there are managers accountable for the product and service
offerings, and if so, tell us who they are accountable to;
 Explain how budgets are prepared, who approves the budget at each step of the process,
the level of detail discussed at each step, and the level at which the CODM makes
changes to the budget;
 Describe the level of detail communicated to the CODM when actual results differ from
budgets and who is involved in meetings with the CODM to discus s budget -to-actual
variances; and,
 Describe the basis for determining the compensation of the individuals that report to the
CODM.

We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that th e 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 the accur acy
and adequacy of the disclosures they have made.

 In responding to our comment , 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

Mr. Anthony T. Skiadas
Verizon Communications Inc.
August 26, 2015
Page 3

  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.

You may contact Sharon Virga, Staff Accountant , at (202) 551 -3385  or Terry French,
Acco untant Branch Chief,  at (202) 551 -3828 or me at (202) 551 -3810 with any questions.

Sincerely,

 /s/ Terry French for

 Carlos Pacho
Senior Assistant Chief Accountant
 AD Office 11 – Telecommunications