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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

 September 23, 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

Forms 10-Q for the Quarterly Periods Ended March 31, 2009 and June 30, 2009

File No. 1-08606

 Dear Mr. Spirgel:

 We have received your comment letter dated August 19, 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 comment one in our letter dated July 9, 2009. We also note the documents dated May 31, 1996 and August 14, 1995 that you have sent us regarding capitalization of
interest for FCC licenses related to PCS business. Please provide a detailed response to the following comments.

a.
 We note in your Form 10-K for December 31, 2008 that you disclose that Verizon Wireless holds FCC licenses to operate several different radio services,
including the cellular radiotelephone service, personal communication

service, advanced wireless service, and point-to-point radio service. Furthermore you state that the technical and service rules, the specific radio
frequencies and amounts of spectrum that you hold and the sizes of the geographic area that you are authorized to operate in, vary for each of these services. Since the interpretation that was previously received related only to PCS licenses under
paragraph 9 of SFAS 142, please provide us with separate information for your licenses by the four aforementioned categories. Further separate each category of license into national licenses and those that pertain to a certain area, specifying the
area to which each relates. For each of the above, show the original cost, capitalized interest if applicable and any other capitalized costs. If the licenses were obtained in a bulk purchase, please show us how you separated them into the
individual components to properly capitalize interest in accordance with SFAS 34.

 Verizon Wireless Licenses

 The Company owns a number of FCC authorized wireless licenses pertaining to wireless radio spectrum. These licenses represent the right to use
designated frequencies in specified areas of the wireless radio spectrum. The designated frequencies are, in general terms, similar and can be used to deliver a wide variety of services. The Company’s licenses include 850 MHz (Cellular)
licenses, 1.9 GHz (PCS) licenses and 1.7/2.1 GHz (AWS) and 700 MHz licenses.

 The 850 MHz licenses are those referred to as cellular radiotelephone service
spectrum in the Company’s 2008 Form 10-K. Cellular licenses are the original licenses that were granted by the FCC approximately 25 years ago. The Company either received these licenses from the FCC without payment in franchise areas where it
was the incumbent wireline telephone carrier, or the Company obtained these licenses through secondary market acquisitions of other wireless companies or licenses owned by other wireless companies. The values recorded in the Company’s financial
statements for these licenses is either zero or the amount of the purchase price allocated to the licenses in accordance with the purchase accounting requirements in effect at the time. No interest has ever been capitalized with respect to these
licenses, which represented $40.6 billion of the $62.0 billion net book value of the Company’s wireless licenses at December 31, 2008. The amount of 850 MHz licenses held by the Company increased by approximately $9.4 billion during 2009
due to the Company’s acquisition of Alltel Corporation.

 1.9 GHz licenses are the licenses referred to as personal communication services (PCS)
spectrum in the Company’s 2008 Form 10-K. These licenses have been used by the Company to provide traditional wireless voice and data services based on 2G and 3G technologies. The Company purchased the PCS licenses in the secondary market
through acquisitions of other wireless companies or licenses owned by other wireless companies, or in auctions conducted by the Federal Government. Approximately $689 million of interest was capitalized through December 31, 2008 with respect to
these licenses, which represented approximately $8.6 billion of the $62.0 billion net book value of the Company’s wireless licenses at December 31, 2008. Since all of the Company’s PCS licenses are ready for their intended use, the
Company no longer capitalizes interest on PCS licenses.

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 The point-to-point radio service licenses referred to in our 2008 Form 10-K do not represent a significant value and no
interest has been capitalized with respect to these licenses.

 The licenses at 1.7/2.1 GHz are referred to as advanced wireless services (AWS) spectrum
licenses. We purchased the AWS licenses in 2006 and the 700 MHz licenses in 2008. The Company intends to use these licenses to provide next generation wireless services based on 4G technology and these licenses are sometimes referred to herein as
“4G licenses”. These licenses were purchased through auctions conducted by the Federal Government. Approximately $618 million of interest has been capitalized through December 31, 2008 with respect to these licenses, which represented
approximately $12.8 billion of the $62.0 billion net book value of the Company’s wireless licenses at December 31, 2008.

 The following is a
summary of the above information as of December 31, 2008 (in billions):

Original
Cost

Capitalized
Interest

Other
Capitalized
Costs

Total
Wireless
Licenses

 Cellular licenses

$
40.6

$
—

$
—

$
40.6

 PCS licenses

7.9

0.7

—

8.6

 4G licenses

12.2

0.6

—

12.8

 Total

$
60.7

$
1.3

$
—

$
62.0

 Because the Company has never or no longer capitalizes interest with respect to its Cellular, PCS and
point-to-point radio service licenses, the remainder of the discussion that follows is directed to what the Company refers to as its 4G licenses and network.

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 The following table sets forth the year-end 2007 and 2008 balances of 4G licenses for which the Company was capitalizing
interest during 2007 and 2008. The table includes all licenses (as designated by the FCC at the time of the auction) with an aggregate cost, as of December 31, 2008, of at least $100 million and for which the three conditions specified in
paragraph 17 of FASB Statement No. 34, Capitalization of Interest Cost (SFAS 34) were met (i.e., licenses which by definition were “qualifying assets”) (in millions).

4G Licenses that are Qualifying Assets

2007

2008

FCC Designated Area

 Mississippi Valley Region

$
275

$
1,901

 Northeast Region

1,335

1,838

 Great Lakes Region

616

1,726

 Chicago

—

1,044

 Southeast Region

572

996

 Central Region

—

723

 Riverside, CA

—

580

 Los Angeles

—

484

 New York

—

430

 West Region

—

320

 Philadelphia

—

248

 Miami

—

233

 Dallas

—

172

 Washington

—

123

 San Francisco

—

104

 Atlanta

—

103

 Houston

—

103

 Tampa

—

102

 None of the licenses purchased by the Company were “national” licenses.

 The individual city licenses shown in the table above provide incremental capacity to the regional licenses. This capacity is necessary to satisfy the expected usage in
large population centers where demand for advanced wireless communications services is generally the greatest. The individual city licenses are all the 700 MHz licenses designated as “A block” and “B block.”

 Phases to Bring Network Into Service

 There are five basic
phases in the process of bringing a new generation wireless network into service. These include (1) the identification of the spectrum resources to be utilized, including, if necessary, the acquisition of additional necessary licenses,
(2) preconstruction activities, (3) construction activities, (4) final testing, and (5) the launch of service. Preconstruction activities

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include (1) the clearing of the licenses, if necessary, (2) the selection and testing of technology to be used, (3) the network design, and
(4) site selection, acquisition and site preparation activities, at either newly acquired network cell site locations, or existing cell site network locations. The first of the preconstruction activities described above (clearing activities)
can vary from license to license although some planning and testing activity is necessary for all licenses to determine the extent to which clearing is necessary. The other preconstruction activities (technology selection and testing activities,
network design activities and site-related activities), however, apply more generally to all licenses throughout the preconstruction process. While certain aspects of the process to bring a network into service must occur in a specific sequence,
other aspects, particularly preconstruction and construction activities, may occur in a specific geographical area simultaneously.

 Once payment has been
made for licenses and interest expense is being incurred, the Company’s policy is to begin capitalizing interest at the time that the preconstruction activities begin. Assuming no interruption in the process, the Company’s policy is to
continue capitalizing interest until the successful completion of final testing. The marketing of commercial services and the acquisition of customers generally begins shortly after the successful completion of final testing.

 In the case of the Company’s 4G network, although certain of the licenses intended for use in the deployment of this network were acquired as early as 2006,
preconstruction activities (and, therefore, interest capitalization on those licenses) did not commence until the third quarter of 2007 and are ongoing at this time.

 During the third quarter of 2009, construction activities that are not dependent on the completion of preconstruction activities commenced in 30 markets in the country where the Company expects to initially launch
service. The construction activities underway include the deployment of Ethernet backhaul capabilities, the addition of capacity to power and environmental control systems, and, where necessary, tower modifications for the mounting of additional
antennas. During the fourth quarter of 2009 or the first quarter of 2010, full network construction is expected to commence in these initial large markets as well as selected smaller markets. Final testing in 25-30 of the initial markets is expected
to be completed during 2010 and in smaller markets in 2011-2013.

 4G Qualifying Activities

 As discussed above, the Company’s 4G network is currently in the preconstruction phase. This phase includes a number of administrative and technical activities that
are summarized above and are necessary to ready the FCC licenses for their intended use. Although the Company considers the activities that are conducted during the preconstruction phases as qualifying activities for interest capitalization as
contemplated in SFAS 34, the cost of these activities are accounted for in accordance with the nature of the activity and not capitalized as part of the cost of the license. The Company does not capitalize interest on the cost of preconstruction
qualifying activities. Interest is only capitalized on the cost of the wireless license.

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 When the Company purchases wireless licenses in Federal auctions, it is not uncommon that the license frequencies are
being used at the time for alternative purposes by another party such as a governmental agency or a radio or television broadcaster. In these instances, the license cannot be used as intended by the Company until the incumbent party stops using the
spectrum. “Clearing” is the general description of the activities that are performed to transfer the operations of the incumbent parties (or terminate the operations completely) from the purchased spectrum to other alternative spectrum.

 The clearing process requires testing to determine the nature and extent of interfering activities. Because the interfering use must be stopped before the
Company can use the licenses, the Company considers the act of “clearing” the preexisting user from the frequency as a qualifying preconstruction activity as defined in paragraph 17.b of SFAS 34. The time it takes to clear spectrum varies
but it typically takes at least one year and can take several years depending on the extent and nature of the interfering activities.

 The spectrum
included in the “4G Licenses that are Qualifying Assets” table above is all intended for use in the Company’s 4G network. The 700 MHz licenses purchased in 2008 were primarily being used by television broadcasters at the time of the
Company’s purchase. These television networks were required to stop using the spectrum by February 2009. This original deadline was extended by Congress, however, and the clearing activities continued until June 2009. The spectrum covered by
the AWS licenses acquired in 2006 was being used by government agencies such as the Department of Defense and the Department of Justice, as well as by private parties for broadcast radio service and commercial point-to-point microwave service. The
clearing activities for the AWS licenses, which began in July 2007, are not yet complete.

 The Staff has questioned whether clearing activities represent
qualifying activities in accordance with the requirements of SFAS 34. The Company concluded that the clearing activities represent preconstruction activities as contemplated in SFAS 34 because they are analogous to the demolition of a pre-existing
structure prior to the construction of a new manufacturing facility.

 Coincident with the clearing activities that began in mid-2007, the Company was also
conducting other qualifying activities as part of the preconstruction phase, such as the design and testing of the 4G network elements necessary for use in the network. The principal 4G network elements are the base stations, the antennas and the
end-user devices. The base stations and antennas are generally part of cell sites and the devices are the phones and data devices used to access the network. The 4G versions of base stations and antennas are not compatible with 2G and 3G devices.
The 4G devices can be designed to work with the 4G network as well as all preexisting 2G or 3G networks. The specifications for each of the 4G network elements are in the process of being determined and the resulting designs are being tested for
compliance and interoperability by company engineers. The preconstruction design and testing phase of the 4G network roll-out has been in process since the third quarter of 2007 and is ongoing. Although the necessary network elements are still
undergoing modification and enhancement, the network element design phase progressed to a point in early 2008 where non-commercial models of these elements were available for preconstruction testing and preconstruction technology trials. During
2008, such trials were conducted using the Company’s AWS license spectrum in Whippany, New Jersey in conjunction with Alcatel-Lucent; Columbus, Ohio in conjunction with Nortel; and Minneapolis, Minnesota in conjunction with Ericsson.

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 These initial preconstruction technical trials have been followed up during 2009 with similar trials in Boston,
Massachusetts with Alcatel-Lucent and in Seattle, Washington with Ericsson utilizing the 700 MHz licenses purchased