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Correspondence

Robert J. Barish

One Verizon Way, 4th Floor

Senior Vice President and Controller

Basking Ridge, NJ 07920

Tel: (908) 559-1629

Fax: (908) 766-5725

robert.barish@verizon.com

 June 26, 2009

 Larry Spirgel

 Assistant Director

 Division of
Corporation Finance

 U. S. Securities and Exchange Commission

 Mail Stop 3720

 Washington, D.C. 20549

Re:

Verizon Communications Inc.

Form 10-K for the Fiscal Year Ended December 31, 2008

Filed February 24, 2009

Form 10-Q for the Quarterly Period Ended March 31, 2009

File No. 1-08606

 Dear Mr. Spirgel:

 We have received your comment letter dated June 4, 2009, and the following represents our response to your comments. For your ease of reference, we have included your comments below and have provided our responses after each comment.

 Form 10-K for the Fiscal Year Ended December 31, 2008

 Management’s Discussion and Analysis of Financial Condition and Results of Operations

 Profitability Improvement

 1. We note your response to prior comment 4. Please include your response in future filings.

 In response to the Staff comment, the Company will include disclosure consistent with the response to prior Comment 4 in the Company’s
applicable future filings.

 Critical Accounting Estimates

 2. We note your response to prior comment 14. We note that for purposes of impairment testing of your wireless licenses, you use the direct income based valuation approach for estimating future discounted cash
flows to determine fair value. Tell us why you believe this methodology is an acceptable methodology to value the licenses. Also tell us how you are able to isolate the cash flows in your discounted cash flow model to be attributed to the licenses.
In your response, please include details about the application of this methodology to the wireless licenses, an indefinite lived intangible, including the assumptions used.

 In accordance with EITF D-108, “Use of the Residual Method to Value Acquired Assets Other Than Goodwill,” (“D-108”) the Company estimates the fair value of its wireless licenses using a direct
value method. In contemplation of its adoption of D-108, which became effective on January 1, 2005, the Company consulted with its independent valuation firm and independent auditors in 2004 and considered its previous discussions with the
Office of the Chief Accountant of the Securities and Exchange Commission (“SEC”) on May 24, 2004 and concluded that the most appropriate direct valuation approach for its wireless licenses was a variation of the income approach
commonly known as the “Greenfield Approach.” The Company has consistently used the Greenfield Approach as its direct income based valuation methodology for estimating the fair value of its wireless licenses since January 1, 2005.

 The Greenfield Approach is a commonly used approach to directly value wireless licenses, broadcast licenses, cable franchise agreements and other similar
intangible assets. The theory underlying this approach is that the owner incurs the start-up costs, initial losses and capital investment needed to create the wireless licenses’ cash flows. This approach directly isolates and values the
wireless licenses as the net present value of the difference between the cash inflows from the operation of the wireless network, principally in the form of service revenues from customers, and the cash outflows required to build and operate a
wireless network.

 In order to add objectivity to the process, the Company retains an independent firm to support the Company’s valuation. The
valuation includes the following steps:

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•

 A discounted cash flow model is constructed to forecast the cash flows from inception, assuming the only asset held is the wireless licenses. The discrete cash
flows are forecasted for the number of years it takes to arrive at a typical representative market penetration level. The cash flows are comprised of forecasted capital expenditures, operating revenues and operating expenses.

•

 Capital expenditures are based on the costs for current and anticipated technology that would be used in the new theoretical network. The build-out is modeled over
the estimated period needed to build the network in order to serve the representative market penetration level.

•

 Revenues are estimated based on the representative market penetration and estimated subscriber usage.

•

 Expenses reflect the costs to attract and retain customers to reach the representative market penetration level and operating costs to serve the customers.

•

 Once the network is built and the representative market penetration rate is reached, a terminal value after this forecast period is estimated based on a constant
growth perpetuity formula or a terminal sale multiple. This terminal value reflects the operations as a going concern.

•

 The future cash flows and terminal value are then discounted to their present value at a rate of return commensurate with the risk inherent in the cash flows.

•

 This present value is the estimated fair value of the wireless licenses as it represents what a willing buyer would pay to purchase the cash flows specifically
related to the wireless licenses at the valuation date.

 The Company believes the Greenfield Approach is the most appropriate valuation
methodology for estimating the fair value of its wireless licenses as it measures what a willing buyer would be willing to pay to purchase only the wireless licenses as of the valuation date. In other words, the Greenfield Approach only includes the
cash flows associated with the build-out and operations of the wireless licenses.

 Notes to Consolidated Financial Statements

 Note 1. Description of Business and Summary of Significant Accounting Policies

 Goodwill

 3. We note from your response to prior comment 17 that you have “operating activities
organized around classes of customers or geographical locations” and that you “collect reliable revenue information and direct cost information for each of these.” However, your reports provided with respect to your response to prior
comment 20 does not appear to contain such information. Tell us who is provided with this information and why. Further, we note your statement that “profitability information is not available at either the customer or regional level.”
Since you have reliable revenue and direct cost information, then you have reliable implied margins, or “profitability information.” Further, if such information is available and is provided to any of the CODMs, it appears that the
information by class of customer or geographic location may meet the definition of an operating segment. Please advise. Refer to paragraphs 13-15 of SFAS 131 in your response.

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 Please refer to the Company’s response to Comment 6.

 Intangible Assets Not Subject to Amortization

 4. We note your response to prior comment 18. SFAS 34
permits the capitalization of interest necessarily incurred to bring a certain qualifying asset to the condition and location necessary for its intended use. Paragraph 9(a) defines qualifying assets as those that are constructed or otherwise
produced for an enterprise’s own use (including assets constructed or produced for the enterprise by others for which deposits or progress payments have been made). It is unclear to us how your wireless licenses meet this definition of
“qualifying assets.” Please tell us in more detail the factors your considered in concluding that these licenses are “qualifying assets.”

 The Company advises the Staff as noted in Paragraph 9a of Statement of Financial Accounting Standards No. 34, Capitalization of Interest Cost (“SFAS No. 34”), that “assets that are
constructed or otherwise produced for an enterprise’s own use (including assets constructed or produced for the enterprise by others for which deposits or progress payments have been made) are ‘qualifying assets’.” The
Company’s wireless licenses are an integral part of its wireless network, which is constructed to provide wireless services to its customers. Accordingly, the Company considers its wireless licenses that are currently in development (along with
the related wireless network) to be qualifying assets under SFAS No. 34. The Company has summarized below its understanding of the treatment of wireless licenses as qualifying assets.

 During 1995 and 1996, representatives from Arthur Andersen held discussions with the Staff regarding a number of issues related to certain wireless
telecommunication registrants, including whether wireless licenses were “qualifying assets” as contemplated by SFAS No. 34. During these discussions the Staff informed Arthur Andersen that it believed that the amount paid for wireless
licenses should be considered qualifying assets under SFAS No. 34. Arthur Andersen subsequently discussed this matter with the other members of the Big 6 accounting firms1. At that time, all of the Big 6 accounting firms agreed that amounts paid for wireless licenses were qualifying assets under SFAS
No. 34. The Company has consistently applied this accounting policy to its wireless licenses since that time.

 In summary, the Company believes that
during their development its wireless licenses meet the characteristics of “qualifying assets” as described in SFAS No. 34 because the Company’s wireless licenses (along with the related wireless network) require a substantial
amount of cost and effort to get them ready for their intended use in the Company’s earnings activities.

1

 Arthur Andersen, Coopers & Lybrand, Deloitte & Touche, Ernst & Young, KPMG Peat Marwick and Price Waterhouse.

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 Note 4. Wireless Licenses, Goodwill and Other Intangible Assets

 Other Intangible Assets

 5. We note your response to
prior comment 19. It appears to us that your response is not considered confidential. Please file this response on EDGAR or advise us in more detail why your request for confidential treatment is appropriate. Tell us your consideration of whether
these amounts are investments rather than non-exclusive licenses since it appears that you have not identified the licenses to which you will have non-exclusive access.

 In response to the Staff’s comment, the Company has revised its response to prior comment 19 to read as follows:

 During 2008, the Company paid $100 million to an investment fund that holds a portfolio of patents and patent applications. Many of these patents and patent applications are relevant to the Company’s business, because they are directed
to wireless and wireline communications services and technologies. The payment provides the Company with the right to use the patents in the conduct of its business, where possible, without additional payment. The $100 million payment is being
amortized over the estimated average remaining life of the patents.

 In a related transaction, the Company agreed to invest up to an additional $250
million in an investment fund that was formed to buy patents and license the patents to investors and other potential parties. The Company’s investment provides the Company with the right to use the patents, where possible, without any
additional payment, in the conduct of its business. Amounts paid under this commitment are included in investments in unconsolidated businesses on the consolidated balance sheet. Any unutilized portion of this commitment expires in 2012. At
March 31, 2009, the Company had invested approximately $48 million in these investment funds.

 There are no other significant costs associated with
these commitments.

 Note 17. Segment Information

 6. We note your response to prior comment 20. Please confirm in writing that you have provided the staff with all of the reports that are provided to your chief operating decision maker (CODM) and that your CODM uses no other
additional reports other than those you provided to us.

 We further note from your response your reference to chief operating decision
makers. Please identify for us who your chief operating decision makers are with specific reference to paragraph 12 of SFAS 131. Also confirm that all of those chief operating decision makers only utilize the reports that you provided to us when
making decisions about resources to be allocated and assessing performance. If any of your chief operating decision makers are provided with other reports that are regularly reviewed by them, please provide such reports to us. Further, tell us in
detail what you believe constitutes being “regularly reviewed” under paragraph 10 b. of SFAS 131.

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 We note from your Form 8-K dated October 27, 2008, containing your announcement of your third quarter results,
that “FiOS was EBITDA positive in the third quarter.” We further note several excerpts from your third quarter earnings conference call that “with regard to FiOS, (you) were on plan both financially and operationally,”
“reducing our structural costs, including access rates in VZB,” “FiOS is on plan and it is actually EBITDA positive this quarter,” and “which is why (you) actually upped some of (y)our own estimates on where (you) think
(you) would be with FiOS.” Finally, we note your Chairman and CEO Ivan Seidenberg’s statement that you “have very, very specific performance metrics that (you) have been meeting now for the past two or three years,” with respect
to your FiOS business. All of these statements appear to imply that more detailed information is available and is being provided to your Chairman and CEO, President and COO, and EVP and CFO. Please advise.

 The Company advises the Staff that its chief operating decision maker (“CODM”), as defined by Financial Accounting Standards No. 131, Disclosures about
Segments of an Enterprise and Related Information (“SFAS No. 131”) is the Company’s Chairman and Chief Executive Officer. The Chairman and CEO determines the Company’s overall business strategy and exercises final
decision-making authority with respect to the allocation of resources and assessment of performance. The Company’s business is organized and operated around its wireless and wireline networks. Cash resources are allocated to enable the delivery
of innovative and advanced services over these networks, to provide for strategic investments and to maintain the desired capital structure and dividend policies. The information included in the monthly report provided to the Staff in the
Company’s response to prior comment 20 represents the primary information provided to the CODM to allocate resources and assess performance.

 In
response to the Staff’s request, the Company is providing a supplemental response relating to another report provided to the CODM under cover requesting confidential treatment pursuant to the provisions of 17 C.F.R. § 200.83. Two versions
of the report are being provided. One version is issued on a monthly basis and the other version is issued on a quarterly basis. The versions are similar except that the quarterly report includes actual and budgeted financial information that is not
included in the monthly report. In addition to this report and the report provided to the Staff in the previous response, the CODM receives information at meetings and in response to ad hoc requests for information throughout the year. The Company
does not believe that this information constitutes information that is regularly reviewed by the CODM, as contemplated by SFAS No. 131.

 The quarterly
report provided to the Staff in this response contains the FiOS EBITDA information referred to by the Staff in its comments. It also contains EBITDA information for one other service, HSI (high speed internet). Although this information is available
to the CODM, it is not used to allocate resources or assess performance, as contemplated by either paragraphs 13 through 15 of SFAS No. 131 or the CODM because EBITDA, by definition, does not include depreciation for the Company’s network,
wh