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CORRESP
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CORRESP

 Verizon Communications Inc.

1095 Avenue of the Americas

New York, New York 10036

 May 26, 2017

 Securities and Exchange Commission

 Division of Corporation
Finance

 100 F Street, N.E.

 Washington, D.C. 20549

Re:

 Verizon Communications Inc. Registration Statement on Form S-4

(File No. 333-218266), filed on May 26, 2017

 Ladies and Gentlemen:

On May 26, 2017, Verizon Communications Inc. (the “Issuer”) filed with the Securities and Exchange Commission (the
“Commission”) a registration statement (File No. 333-218266) (the “Registration Statement”) on Form S-4 under the Securities Act
of 1933, as amended (the “Securities Act”). The Registration Statement registers (i) $3,194,253,000 in aggregate principal amount of the Issuer’s new 2.946% Notes due 2022 (the “2022 Exchange Notes”) to be
exchanged in an exchange offer for a like principal amount of the Issuer’s outstanding 2.946% Notes due 2022 (the “2022 Initial Notes”), (ii) $1,706,360,000 in aggregate principal amount of the Issuer’s new 4.812%
Notes due 2039 (the “2039 Exchange Notes”) to be exchanged in an exchange offer for a like principal amount of the Issuer’s outstanding 4.812% Notes due 2039 (the “2039 Initial Notes”) and
(iii) $4,072,197,000 in aggregate principal amount of the Issuer’s new 5.012% Notes due 2049 (the “2049 Exchange Notes” and, together with the 2022 Exchange Notes and the 2039 Exchange Notes, the “Exchange
Notes”) to be exchanged in an exchange offer for a like principal amount of the Issuer’s outstanding 5.012% Notes due 2049 (the “2049 Initial Notes” and, together with the 2022 Initial Notes and the 2039 Initial Notes,
the “Initial Notes”). The exchange offers are referred to collectively as the “Exchange Offer”. We are submitting this letter in order to inform you that the Issuer is registering the Exchange Offer in reliance on
the position of the staff of the Commission (the “Staff”) stated in the Exxon Capital Holdings Corporation, SEC No-Action Letter (available May 13, 1988) (the “Exxon
Capital Letter”), Morgan Stanley & Co. Incorporated, SEC No-Action Letter (available June 5, 1991) (the “Morgan Stanley Letter”) and
Shearman & Sterling, SEC No-Action Letter (available July 2, 1993) (the “Shearman & Sterling Letter”). In connection with the
filing of the Registration Statement and in anticipation of the acceleration of the effectiveness thereof, the Issuer hereby represents as follows:

The Issuer has not entered into any arrangement or understanding with any person to distribute the Exchange Notes to be received in the
Exchange Offer and to the best of the Issuer’s information and belief, each person participating in the Exchange Offer is acquiring the Exchange Notes in its ordinary course of business and has no arrangement or understanding with any person to
participate in the distribution of the Exchange Notes to be received in the Exchange Offer. In this regard, the Issuer will make each person participating in the Exchange Offer aware (through the Exchange Offer prospectus or otherwise) that any
securityholder using the Exchange Offer to participate in a distribution of the Exchange Notes to be acquired in the Exchange Offer (1) cannot rely on the Staff’s position in the Exxon Capital Letter, the Morgan Stanley Letter, the
Shearman & Sterling Letter or similar letters and (2) must comply with registration and prospectus delivery requirements of the Securities Act in connection with a secondary resale transaction. The Issuer acknowledges that such a
secondary resale transaction should be covered by an effective registration statement containing the selling securityholder information required by Item 507 of Regulation S-K under the Securities Act.

 The Issuer will also include in the letter of transmittal to be executed by each person
participating in the Exchange Offer (the “Letter of Transmittal”) disclosure that, by accepting the Exchange Offer, each holder (including any broker-dealer) of the Initial Notes represents to the Issuer that (i) it is not an
affiliate of the Issuer, or if an affiliate of the Issuer, will comply with the registration and prospectus delivery requirements of the Securities Act to the extent applicable in connection with the resale of the Exchange Notes, (ii) the
Exchange Notes will be acquired in the ordinary course of business, and (iii) it is not engaged in, and does not intend to engage in, a distribution of the Exchange Notes to be received in the Exchange Offer.

With respect to any broker-dealer participating in the Exchange Offer with respect to the Initial Notes acquired for its own account as a
result of market-making activities or other trading activities, each such broker-dealer must confirm that it has not entered into any arrangement or understanding with the Issuer or any affiliate of the Issuer to distribute the Exchange Notes. In
addition, the Issuer (i) will make each person participating in the Exchange Offer aware (through the Exchange Offer prospectus or otherwise) that any broker-dealer who holds Initial Notes acquired for its own account as a result of
market-making activities or other trading activities, and who receives Exchange Notes in exchange therefor pursuant to the Exchange Offer, may be a statutory underwriter and must deliver a prospectus meeting the requirements of the Securities Act in
connection with any resale of such Exchange Notes, and (ii) will include in the Letter of Transmittal the additional requirement that if the exchange offeree is a broker-dealer holding Initial Notes acquired for its own account as a result of
market-making activities or other trading activities, an acknowledgment that such broker-dealer will deliver a prospectus meeting the requirements of the Securities Act in connection with any resale of Exchange Notes received in respect of such
Initial Notes pursuant to the Exchange Offer. The Letter of Transmittal will also include a statement to the effect that by so acknowledging and by delivering a prospectus, a broker-dealer will not be deemed to admit that it is an
“underwriter” within the meaning of the Securities Act.

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Very truly yours,

VERIZON COMMUNICATIONS INC.

 /s/ William L. Horton, Jr.

Name:

William L. Horton, Jr.

Title:

Senior Vice President, Deputy General Counsel & Corporate Secretary