SEC Comment Letter for VERIZON COMMUNICATIONS INC (VZ) (CIK 0000732712) (VZ) — Aug 28, 2018
VERIZON COMMUNICATIONS INC (VZ) (CIK 0000732712)
Date: Aug. 28, 2018 · CIK: 0000732712 · Accession: 0000000000-18-026757
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File numbers found in text: 001-08606
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August 28, 2018
Anthony 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 the Fiscal Year Ended December 31, 2017
Filed February 23, 2018
File No. 001-08606
Dear Mr. Skiadas:
We have limited our review of your filing to the financial statements and related
disclosures and have the following comment. Please comply with the following comment in
future filings.
Please respond to this comment within ten business days by providing the requested
information or advise us as soon as possible when you will respond. If you do not believe our
comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this comment, we may have additional comments.
Form 10-K for the Fiscal Year Ended December 31, 2017
Management’s Discussion and Analysis of Financial Condition and Results of Operations
Consolidated Net Income, Operating Income and EBITDA
1.Your presentation of the non-GAAP measure titled, "Consolidated EBITDA" excluding
other income (expense) and equity in losses of unconsolidated businesses is inconsistent
with question 103.01 of the updated Compliance, Disclosure and Interpretation guidance
on non GAAP measures last updated on April 4, 2018. Please comply with this comment
in future filings and in your next earnings release.
In closing, we remind you that the company and its management are responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or
absence of action by the staff.
FirstName LastNameAnthony Skiadas
Comapany NameVerizon Communications Inc
August 28, 2018 Page 2
FirstName LastName
Anthony Skiadas
Verizon Communications Inc
August 28, 2018
Page 2
You may contact Inessa Kessman, Senior Staff Accountant at 202-551-3371 or Terry
French, Accounting Branch Chief at 202-551-3828 with any questions.
Sincerely,
Division of Corporation Finance
Office of Telecommunications