SEC Company Response from VERIZON COMMUNICATIONS INC (VZ) (CIK 0000732712) (VZ) — Nov 9, 2011
VERIZON COMMUNICATIONS INC (VZ) (CIK 0000732712)
Date: Nov. 9, 2011 · CIK: 0000732712 · Accession: 0001193125-11-304758
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-08606
Referenced dates: November 8, 2011
Letter
Division of Corporation Finance Re: Verizon Communications Inc. Form 10-K for the Fiscal Year Ended December 31, 2010 Filed February 28, 2011 File No. 001-08606
Dear Mr. Spirgel:
I am writing with reference to our letter dated November 8, 2011, in which we indicated that in the future Verizon will (i) treat any amounts awarded with respect to the portion of Mr. Seidenberg’s 2008-2010 PSU Award that is subject to the Addendum to his Long Term Incentive Award Performance Stock Unit Agreement for the 2008-2010 award cycle and any similar strategic component of Mr. Seidenberg’s other equity incentive plan awards as stock awards granted on the last day of the applicable performance cycle and (ii) report such awards in the Stock Awards column of the Summary Compensation Table for the applicable year. This letter confirms that, in its proxy statement for the 2012 Annual Meeting of Shareholders, Verizon will include amounts awarded with respect to the strategic components of Mr. Seidenberg’s 2007-2009 PSU award and 2008-2010 PSU award in the Stock Awards columns of the 2009 and 2010 line items, respectively, of the Summary Compensation Table. If any amount is awarded with respect to the strategic component of Mr. Seidenberg’s 2009-2011 PSU award, that amount will similarly be reflected in the Stock Awards column of the 2011 line of the Summary Compensation Table.
* * * * *
The Company acknowledges that:
•
it is responsible for the adequacy and accuracy of the disclosures in its filings;
•
Staff comments or changes to disclosures in response to Staff comments do not foreclose the Commission from taking any action with respect to the filings; and
•
it 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.
Correspondence regarding this letter may be directed to the attention of the undersigned at fax number (908) 766-5725. In addition, you may contact me at (908) 559-1629 or Michael Morrell at (908) 559-1200.
Sincerely,
/s/ Robert J. Barish
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CORRESP 1 filename1.htm 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 November 9, 2011 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, 2010 Filed February 28, 2011 File No. 001-08606 Dear Mr. Spirgel: I am writing with reference to our letter dated November 8, 2011, in which we indicated that in the future Verizon will (i) treat any amounts awarded with respect to the portion of Mr. Seidenberg’s 2008-2010 PSU Award that is subject to the Addendum to his Long Term Incentive Award Performance Stock Unit Agreement for the 2008-2010 award cycle and any similar strategic component of Mr. Seidenberg’s other equity incentive plan awards as stock awards granted on the last day of the applicable performance cycle and (ii) report such awards in the Stock Awards column of the Summary Compensation Table for the applicable year. This letter confirms that, in its proxy statement for the 2012 Annual Meeting of Shareholders, Verizon will include amounts awarded with respect to the strategic components of Mr. Seidenberg’s 2007-2009 PSU award and 2008-2010 PSU award in the Stock Awards columns of the 2009 and 2010 line items, respectively, of the Summary Compensation Table. If any amount is awarded with respect to the strategic component of Mr. Seidenberg’s 2009-2011 PSU award, that amount will similarly be reflected in the Stock Awards column of the 2011 line of the Summary Compensation Table. * * * * * The Company acknowledges that: • it is responsible for the adequacy and accuracy of the disclosures in its filings; • Staff comments or changes to disclosures in response to Staff comments do not foreclose the Commission from taking any action with respect to the filings; and • it 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. Correspondence regarding this letter may be directed to the attention of the undersigned at fax number (908) 766-5725. In addition, you may contact me at (908) 559-1629 or Michael Morrell at (908) 559-1200. Sincerely, /s/ Robert J. Barish Robert J. Barish Senior Vice President and Controller cc: Paul Beswick Terry French Jonathan Groff Thomas Kim Anne Krauskopf James Kroeker Joel Levine Carlton Tartar Sharon Virga Francis J. Shammo Page 2 of 2