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Correspondence

 Robert J. Barish

 Senior Vice President and Controller

 One Verizon Way, 4th Floor

 Basking Ridge, NJ 07920

 Tel:        (908) 559-1629

 Fax:        (908) 766-5725

 robert.barish@verizon.com

 July 31, 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 July 9, 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

 Notes to Consolidated Financial Statements

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

 Intangible Assets Not Subject to Amortization

 1. We note your response to prior comment 4. As previously requested, please tell us in greater detail how you evaluated the factors in SFAS 34 in concluding that
the licenses are “qualifying assets.” In addition, please provide us with the following information as of the end of each of the last five fiscal years and the first quarter of 2009:

•

 The nature and balance of each of the following: 1) the license balance that you believe is a qualifying asset and which you used to compute capitalized
interest AND 2)

related qualifying asset (asset group) balance for which you capitalized interest. Explain in detail the nature of the related assets that you are
constructing or constructed in previous years.

•

 The amount of interest capitalized for each of 1) your license balance and 2) related asset (asset group) balance.

•

 The amount of capitalized interest amortized for each of your related asset (asset group) balance.

 Wireless licenses provide the Company with an exclusive right to utilize designated radio frequency spectrum (“wireless spectrum”) to provide wireless
communications services. The wireless licenses are an integral part of the Company’s wireless communication network which has been constructed to provide robust, nationwide wireless services to our customers. Once wireless licenses, which
represent the right to use the wireless spectrum, have been acquired, the network needs to be completed through the construction and deployment of technology and equipment that will enable the Company to provide wireless communication services to
its customers. The Company believes that its wireless licenses are qualifying 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 payment have been made),” as defined in Paragraph 9.a of Statement of Financial Accounting Standards No. 34, Capitalization of Interest Cost (“SFAS No. 34”). Additionally, the Company
believes based on disclosures of other public registrants that its accounting policy with respect to capitalization of interest on its wireless licenses in development for commercial service is the predominant industry practice.

Assets qualifying for interest capitalization generally are those that require a period of time to prepare them for their intended use. As noted in SFAS No. 34,
paragraph 6, “If an asset requires a period of time in which to carry out the activities necessary to bring it to that condition and location, the interest cost incurred during that period as a result of expenditures for the asset is a part of
the historical cost of acquiring the asset.” In addition, paragraph 12 of SFAS No. 34 indicates that “the amount of interest cost to be capitalized for qualifying assets is intended to be that portion of interest cost incurred during
the assets’ acquisition periods that theoretically could have been avoided … if expenditures for the assets had not been made.”

 In
connection with providing wireless services, there are a number of activities that occur in preparing acquired wireless spectrum for the provision of wireless communication services. These activities can occur sequentially or, for some activities,
simultaneously depending on the circumstances. In many cases, there are existing users of the wireless spectrum who need to be cleared and, in some cases, relocated to other wireless spectrum prior to the Company’s use of the wireless spectrum.
Feasibility and engineering studies are performed to select the nature and extent of technology to be deployed, and vendor selection and field trials are conducted. These activities include testing devices to ensure they function properly –
first in a lab environment and then in the field. Then equipment acquisition and deployment activities are undertaken, which includes working with equipment providers to develop and test cell site equipment and deploying it to cell sites in the
licensed area. The wireless network components include various types of equipment, such as base stations, transmission facilities and the core network elements. A typical base station includes antennas that transmit and receive signals to end-user
devices, radio equipment, backup power, transmission equipment, cabling, shelter and tower. The base station

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is connected to the core network equipment via transmission facilities such as copper wire, fiber, or microwave. Typical core network elements include
switching and routing equipment, databases, servers, service delivery platforms, backup power, transmission equipment and shelters to house the equipment. Only after all of the activities described above are completed are final testing and
commercial launch possible.

 In accordance with Paragraph 17 of SFAS No. 34, “The term activities is to be construed broadly. It
encompasses more than physical construction; it includes all the steps required to prepare the asset for its intended use. For example, it includes administrative and technical activities during the preconstruction stage, such as the development of
plans or the process of obtaining permits from governmental authorities; it includes activities undertaken after construction has begun in order to overcome unforeseen obstacles, such as technical problems, labor disputes, or litigation.” The
activities listed above are considered qualifying activities in the development of wireless licenses because these activities are necessary to permit the intended commercial use of the wireless licenses.

 Because the purchase of wireless licenses required a cash payment, it is consistent with the first condition for beginning to capitalize interest cost as noted in
paragraph 17 of SFAS No. 34. When qualifying activities, which are necessary to get the wireless license ready for its intended use, are in progress, they meet the second condition in paragraph 17 of SFAS No. 34. Finally, as the Company
has net debt outstanding, on which interest costs are incurred, the third condition for commencing the capitalization of interest cost is present. As such, the period of time for which interest is capitalized commences once qualifying activities
have begun and ends when the wireless spectrum and related assets are able to satisfactorily provide wireless communications services. The wireless spectrum and related wireless plant equipment are considered to be able to provide wireless
communications services when they are able to pass a performance test. If activities are substantially suspended, interest capitalization ceases until the qualifying activities are resumed. The Company has a process in place to monitor these
qualifying activities.

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 In response to the Staff’s comment the following information is being provided:

 (in millions)

3/31/09

12/31/08

12/31/07

12/31/06

12/31/05

12/31/04

 Total Wireless Licenses

$
70,873

$
61,974

$
50,796

$
50,959

$
47,781

$
42,067

 Qualifying Wireless Licenses

12,233

12,395

2,978

4,036

4,356

1,399

 Total Wireless Plant, Property and Equipment (“PP&E”)

56,584

52,124

50,887

46,411

42,018

36,914

 Qualifying Wireless PP&E

1,785

1,701

1,864

1,998

1,539

1,385

 Capitalized Interest

 Wireless Licenses

$
184

$
557

$
203

$
240

$
181

$
48

 Wireless PP&E

24

62

92

78

67

70

 Interest amortization related to Wireless PP&E

17

67

60

55

52

49

 During 2008, the Company acquired 700 MHz wireless licenses necessary to develop and offer fourth generation voice
and data wireless services to its customers. Approximately $9 billion of the Company’s wireless license balance at March 31, 2009 was attributable to these 700 MHz licenses. The process is underway for clearing the wireless spectrum and
the feasibility and engineering studies necessary to place the licenses into service have begun. Equipment acquisition and deployment activities related to this wireless spectrum have also recently begun. The detailed types of qualifying activities
that the Company has undertaken with respect to these licenses include: interference analysis, incumbent relocation, coordination with federal government and prior coordination notification to incumbents, filing base station data with the
appropriate clearinghouses, site selection, site leasing and acquisition, real estate zoning and permitting, radio frequency system design, usage studies, fixed network design, and switch and service planning.

 Note 4. Wireless Licenses, Goodwill and Other Intangible Assets

 Other Intangible Assets

 2. We note your response to prior comment 5. Tell us why you are not amortizing your $100 million
payment for access to a portfolio of patents and patent applications based on the weighted average remaining lives of these patents. For the $250 million that you may invest in an investment fund to buy patents and license the patents to various
parties, please tell us and disclose the nature of your commitment, including your potential liability for amounts not yet

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invested. Tell us and disclose why you believe that this is an investment when your payment provides access to these patents without additional charge.

 The Company advises the Staff that it is amortizing the $100 million payment for access to the patent portfolio over the estimated average
remaining life of the patents in the portfolio. The Company reviewed the patents in the portfolio and determined that the estimated average remaining useful life was approximately 12 years. Based on the Company’s evaluation, it does not believe
that the use of other available amortization methods, such as the use of a weighted average remaining life, would result in a materially different amount of annual amortization.

 The Company also advises the Staff that the capital commitment of $250 million to the investment fund is the maximum amount the Company may be obligated to contribute under the subscription agreement, as disclosed in
Note 4 to the Condensed Consolidated Financial Statements as filed in the Company’s Form 10-Q for the period ending June 30, 2009. If any portion of the unfunded capital commitment is not called prior to 2012, the commitment with respect
to that unfunded amount will terminate, and the Company will not be obligated to make any further contributions to the investment fund. The amount of the commitment that had been called at June 30, 2009 was $58 million.

 Based on the terms of the agreement, the Company performed an analysis to allocate the $250 million capital commitment between the amount that represents an investment
and the amount that represents an intangible asset based on the right to use the patents being acquired by the fund. The amount allocated to the investment was based on the estimated future cash flows that the Company expects to receive from the
fund. The amount attributable to the right to use the patents is being amortized over the expected average remaining useful life of the patents, currently estimated to be approximately 12 years. As the fund acquires additional patents over the term
of the fund, the Company will continue to review the appropriateness of the remaining estimated useful life and make adjustments as required.

 Note
17. Segment Information

 3. We note your response to prior comments 3 and 6. Please address the following comments.

•

 In our prior comment we had requested all reports and information provided to your CODM. Please provide these reports. At this time we do not want to
parse the word “regularly.” Please confirm to us that you provided us with all the information your CODM gets that provides him with the information about FiOS and HSI that was used for the comments in the documented earnings call with
analysts.

•

 We note your statement that the CODM utilizes network-level financial measures to allocate resources and assess performance between its wireline and wireless
operations. Please tell us in detail how resources are allocated and performance is assessed within both your wireline and wireless operations.

•

 We note that you have Presidents within your wireline operations for Verizon Telecom, Verizon Business and Verizon Services. Please tell us why each President
is not considered part of the CODM group under paragraph 12 of SFAS 131 or segment manager under paragraph 14 of SFAS 131.

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 We acknowledge the Staff’s request for all reports that are provided to our CODM, regardless of whether such reports
are provided on a “regular” basis. However, determining whether reports are provided to the CODM on a regular basis is necessary in order to properly apply paragraph 10 of Statement of Financial Accounting Standards No. 131,
Disclosures about Segments of an Enterprise and Related Information (“SFAS No. 131”), which states, in part, that “An operating segment is a component of an enterprise … whose operating results are regularly reviewed
by the enterprise’s CODM to make decisions about resources to be allocated to the segment and assess its performance ….” Accordingly, the Company confirms that it has previously provided to the Staff all of the reports that are
regularly reviewed by the CODM to make decisions about allocating resources and assessing performance, as well as all of the reports provided to the CODM regarding FiOS and HSI that were used for the comments in the documented earnings call with
analysts.

 As previously noted to the Staff, the Company’s CODM is its Chairman and Chief Executive Officer. The Company does not consider the CODM
responsibility to be a shared responsibility and does not operate its business in that manner. The CODM allocates resources and assesses performance, has final decision making authority and is able to override decisions made by others within the
organization; therefore, the CODM has complete control over all operating decisions. The Company’s segment manager for its Wireline segment is its President and Chief Operating Officer who is directly accountable to and maintains regular
contact with the CODM to discuss operating activities, financial results, and plans for the segment. The Wireline segment manager is responsible for using the resources allocated to him by the CODM and for executing operating decisions made by the
CODM. The Company considers the individuals referred to in the Staff’s comment to be among those responsible for executing the directives from the Wireline segment manager for specific revenue channels and, in the case of Verizon Services,
network activities. All three are interdependent groups that contribute to, but cannot independently achieve, the Wireline revenue growth and adjusted operating income objectives.

 The primary measures used by the CODM to assess performance are revenue growth and adjusted operating income. These are assessed at both the consolidated level an