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SEC Correspondence

 Anthony T. Skiadas

Senior Vice President and Controller

 Verizon Communications Inc.

 1095 Avenue of the Americas

New York, New York 10036

Phone 908 559-5741

 tony.skiadas@verizon.com

 September 22, 2015

Mr. Carlos Pacho

Senior Assistant Chief Accountant

AD Office 11 – Telecommunications

 U.S.
Securities and Exchange Commission

 Mail Stop 3720

 Washington, DC 20549

Re:
Verizon Communications Inc.

Form 10-K for Fiscal Year Ended December 31, 2014

Filed February 23, 2015

File No. 1-08606

 Dear Mr. Pacho,

Verizon Communications Inc. (“Verizon”, the “Company”, “we”) respectfully provides the following response to the comments
contained in the letter (the “Comment Letter”) of the staff of the Division of Corporate Finance (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”), dated August 26, 2015, relating to
the above-referenced filing.

 To facilitate review, we have repeated the text of each of the Staff’s comments below and followed each comment with the
Company’s response.

 Form 10-K for the fiscal year ended December 31, 2014

Exhibit 13

 Note 14. Segment Information

You disclose that you have operations in two reportable segments, Wireless and Wireline. We note on page 8 that you organize your Wireline service and product
offerings by the primary customers targeted. In addition we note the remarks in your earnings calls of the impact on operating results of the FiOS platform. To help us understand how you applied the guidance in FASB ASC 280 in identifying your
operating segments, please provide us with the following information:

●

Provide your organization chart which identifies the positions, roles, or functions that report directly to your chief operating decision maker (“CODM”) and senior management team;

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●

Tell us the title and describe the role of your CODM and each of the individuals who report to the CODM;

●

Identify for us each of the operating segments you have determined in accordance with FASB ASC 280;

●

Identify and describe the role of each of your segment managers;

●

Tell us how often the CODM meets with his/her direct reports, the financial information the CODM reviews to prepare for those meetings, the financial information discussed in those meetings, and who attends
those meetings;

●

Describe the information regularly provided to the CODM and tell us how frequently it is prepared;

●

Describe the information regularly provided to the Board of Directors and tell us how frequently it is prepared;

●

Describe the information about Wireline’s product and service offerings that are provided to the CODM, tell us whether there are managers accountable for the product and service offerings, and if so, tell
us who they are accountable to;

●

Explain how budgets are prepared, who approves the budget at each step of the process, the level of detail discussed at each step, and the level at which the CODM makes changes to the budget;

●

Describe the level of detail communicated to the CODM when actual results differ from budgets and who is involved in meetings with the CODM to discuss budget-to-actual variances; and,

●

Describe the basis for determining the compensation of the individuals that report to the CODM.

 In
responding to the Staff’s comment, we believe it will be helpful to describe our application of FASB ASC 280, including our basis for concluding that we have two operating segments which are also our reportable segments as of December 31,
2014. We believe this background information will help the Staff to understand how our chief operating decision maker (“CODM”) utilizes information to make key operating decisions and assess performance. We respectfully advise the Staff
that the Company’s determination of its operating segments is consistent with its management approach and the specific criteria of what constitutes an operating segment in accordance with FASB ASC 280.

OVERVIEW OF SEGMENT OPERATIONS

 Below we describe the significant aspects of
each of our Wireless and Wireline businesses with a focus on our Wireline business.

 Network

The Company is organized and managed around its Wireless and Wireline communications networks. The Wireless network is domestic in nature and covers virtually all of
the population of the United States. The Wireline network is largely domestic in nature and although its revenues are substantially domestic it does have some international reach. Although the Wireless and Wireline networks have certain common
elements, such as fiber connectivity, they remain largely separate at this time, and as of December 31, 2014, were individually managed by two Segment Managers who reported directly to the Company’s Chairman and Chief Executive Officer
(“CEO”). The Segment Manager for

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Wireless was the Executive Vice President (“EVP”) and President and CEO Verizon Wireless. The Segment Manager for Wireline was the EVP and President Global Enterprise and Consumer
Wireline.

 Our Wireless and Wireline communications networks represent our most strategic assets. We made capital investments of $8.9 billion, $9.4 billion and
$10.5 billion in our Wireless communications network during 2012, 2013 and 2014, respectively. We made capital investments of $6.3 billion, $6.2 billion and $5.8 billion in our Wireline communications network during 2012, 2013 and 2014,
respectively. In addition, depreciation of our networks and cost of network management are significant expenses of our segments, representing approximately 14% and 21% of Wireless and Wireline segment expenses during 2014, respectively.

Products and Services

 Through each of our operating segments, we provide a
variety of products and services which are delivered to our customers over our common Wireless or Wireline communications networks.

 Wireless

Our Wireless segment, with operating revenues of $87.6 billion in 2014, provides wireless communications services across one of the most extensive wireless networks in
the United States. We provide these services and equipment sales to consumer, business and government customers in the United States on a postpaid and prepaid basis. Postpaid connections represent individual lines of service for which a customer is
billed in advance a monthly access charge in return for a monthly network service allowance, and usage beyond the allowance is billed monthly in arrears. Our prepaid service enables individuals to obtain wireless services without a long-term
contract or credit verification by paying for all services in advance. In addition, we offer companies access to our wireless network to provide wireless connections for their machine-to-machine devices.

Wireline

 In our Wireline segment, we deliver our product and service
offerings across a common Wireline communication network. We organize these products and services based on the customer groups – Mass Markets, Global Enterprise and Global Wholesale – to whom they are marketed and delivered.

●

Our Mass Markets product and service offerings, which accounted for operating revenues of $18.0 billion in 2014, include various offerings to residential and small business subscribers. These offerings include broadband
services (including High-speed Internet, FiOS Internet and FiOS Video services), local exchange (basic service and end-user access) and long distance (including regional toll) voice services to residential and small business subscribers.

●

Our Global Enterprise product and service offerings, which accounted for operating revenues of $13.7 billion in 2014, include offerings to medium and large domestic and multinational businesses, such as networking
products and solutions, advanced communication services for voice and data as well as cloud services.

●

Our Global Wholesale product and service offerings, which accounted for operating revenues of $6.2 billion in 2014, include offerings to local, long distance and other carriers that use our facilities to provide
services to their customers, such as data, voice and broadband services.

 Centralized Functions

A significant portion of our costs relate to centralized functions and activities, such as network operations, engineering, information technology, human resources,
marketing and branding, real estate management, sourcing, and other corporate managed functions and activities. These costs are allocated to or within the operating segments. We also incur certain direct costs with respect to

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our product and service offerings, such as, content costs, sales related costs and certain access costs, as well as other costs. We track these costs, along with associated revenues, to arrive at
a Contribution Margin for each of our Wireline customer groups. Approximately half of the expenses in the Wireline segment are not direct costs of our products and services but are directly or indirectly incurred to support the Wireline network or
Wireline segment activities.

 DETERMINATION OF CHIEF OPERATING DECISION MAKER

Based on the Company’s organizational structure and assignment of responsibilities, the Company’s Chairman and CEO determines the Company’s overall
business strategy and is responsible for decisions with respect to the allocation of resources and assessment of performance. In addition, the Chairman and CEO leads all strategic and key operational aspects of the Company’s Wireless and
Wireline businesses, evaluates the performance of the Segment Managers and makes decisions about the allocation of resources to the operations the Segment Managers manage. As such, the Chairman and CEO is the Company’s CODM.

The CODM’s responsibility is not a shared responsibility. Furthermore, although certain decisions made by the Chairman and CEO require approval of Verizon’s
Board of Directors, these decisions are consistent with general corporate governance requirements, such as the purchase or disposition of significant assets and the approval of the Company’s annual aggregate capital budget, and do not include
decisions that are related to the normal allocation of resources and performance assessment.

 ORGANIZATIONAL REPORTING

As of December 31, 2014, Verizon had two Segment Managers – one responsible for Wireless and one responsible for Wireline. The Segment Manager for Wireline
was the EVP and President Global Enterprise and Consumer Wireline. The Segment Manager for Wireless was the EVP and President and CEO Verizon Wireless. Both of these Segment Managers reported directly to the CODM.

In addition to the Segment Managers noted above, as of December 31, 2014, the following leaders reported directly to the Company’s Chairman and CEO:

●

EVP and Chief Financial Officer

●

EVP - Strategy, Development and Planning

●

EVP and Chief Information Officer

●

EVP - Public Policy and General Counsel

●

EVP and Chief Administrative Officer

●

EVP and Chief Technology Officer

●

EVP and President - Product and New Business Innovation

●

EVP and Chief Marketing Officer

 Please reference Exhibit A for the Company’s organization chart identifying the
positions, roles, and functions that report directly to the Company’s Chairman and CEO.

 Early in the first quarter of 2015, the Company reorganized the roles
and responsibilities of certain executive management personnel which resulted in one executive – our EVP and President of Operations – being responsible for the operations of both the Wireless and Wireline segments.

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 This reorganization did not result in a change in our operating segments because it did not impact the determination of
our CODM or how our CODM manages our businesses and makes decisions. The positions resulting from the Company’s organizational realignment were the ones included in our Form 10-K for the fiscal year ended December 31, 2014. Please
reference Exhibit B for the Company’s organization chart effective for the first quarter 2015.

 OVERVIEW OF INFORMATION USED BY CODM TO ASSESS OPERATING
PERFORMANCE, ALLOCATE RESOURCES, AND MAKE DECISIONS

 The primary measure used by the Company’s CODM to assess performance and allocate resources is
Adjusted Operating Income. Adjusted Operating Income is used because this performance measure contains significant network-related costs, namely depreciation and network management costs, as well as the costs of each segment’s centralized
functions and allocated corporate expenses. Adjusted Operating Income is calculated by excluding the effect of non-operational items (e.g., benefit actuarial gains and losses, gains and losses arising from strategic transactions) from the
calculation of operating income. This measure is reported to and evaluated by the CODM at the Wireline, Wireless and consolidated Company levels.

 In addition to
Adjusted Operating Income, the Company’s CODM is provided with additional financial measures related to the Company’s operations. Such other measures include, at the operating segment level, earnings before interest, taxes, depreciation
and amortization (“EBITDA”). EBITDA is determined and presented as a measure of profit at the segment level for Wireless and Wireline; however, it is not the primary measure used by the CODM as it does not include depreciation and
amortization expenses that are included in Adjusted Operating Income.

 The Company’s determination of its operating segments is consistent with its management
approach and the specific criteria of what constitutes an operating segment in accordance with FASB ASC 280. The CODM makes key operating and budgeting decisions at the Wireless and Wireline operating segment level because substantially all of the
Company’s products and services are delivered over, and revenues are generated by, its Wireless and Wireline communications networks. The performance of these two networks is critical to the success of our product and service offerings and
therefore is an integral factor when the CODM assesses financial performance and makes key operating and budgeting decisions.

 RESPONSES TO INDIVIDUAL STAFF
QUESTIONS

 The Company has concluded that the Wireless and Wireline businesses are operating segments as defined in FASB ASC 280. To facilitate the Staff’s
understanding of how the Company has applied the guidance in FASB ASC 280 in identifying these operating segments, please see our responses below to the Staff’s comments.

●

Provide your organization chart which identifies the positions, roles, or functions that report directly to your chief operating decision maker (“CODM”) and senior management team

 Please reference Exhibit A. The organization chart and discussion of roles and responsibilities reflect the Company’s leadership team as of
December 31, 2014. Exhibit B includes an organizational chart and discussion of roles and responsibilities of the leadership team following the management reorganization in the first quarter of 2015.

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●

Tell us the title and describe the role of your CODM and each of the individuals who report to the CODM

Please reference Exhibit A and B and the response above.

●

Identify for us each of the operating segments you have determined in accordance with FASB ASC 280

 We
respectfully advise the Staff that, in accordance with FASB ASC 280-10-50-1, the Company has determined it has two operating segments, Wireless and Wireline, as of and for the year ended December 31, 2014 because they have the following
characteristics:

a)
They have business activities from which revenues are earned and expenses are incurred;

b)
Their operating results a