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                              DAVIS & GILBERT LLP
                                 1740 BROADWAY
                            NEW YORK, NEW YORK 10019

DIRECT DIAL NUMBER                                          MAIN FACSIMILE
(212) 468-4944                                              (212) 468-4888
 EMAIL ADDRESS                                            PERSONAL FACSIMILE
rnorton@dglaw.com                                           (212) 974-6969

                                                        November 13, 2009

VIA EMAIL AND EDGAR

Cecilia Blye, Esq., Chief
Office of Global Security Risk
Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, D.C. 20549

                Re:     WPP plc
                        Form 20-F for the Fiscal Year Ended December 31, 2008
                        Filed May 12, 2009
                        File No. 0-16350

Dear Ms. Blye:

     On behalf of WPP plc (the "Company"),  this letter responds to the comments
received from the Division of Corporation Finance of the Securities and Exchange
Commission (the "Commission") in a letter dated September 30, 2009 (the "Comment
Letter")  pertaining to the captioned report on Form 20-F. For ease of reference
in this letter,  the Commission's  comments  contained in the Comment Letter are
reproduced in bold in numerical  sequence in this letter,  and the corresponding
responses of the Company are shown below each comment.

     1.   It  appears  from your  website  and the  websites  of certain of your
          subsidiaries that some of your divisions and subsidiaries have offices
          in Damascus,  Syria.  It appears from various news  articles and other
          public sources that certain of your  subsidiaries have offices in Iran
          or Syria, and have engaged in business activities associated with Iran
          and Cuba.

          We note that your Form 20-F does not discuss contacts with Iran, Syria
          and Cuba.  Iran, Syria and Cuba are identified by the State Department
          as state  sponsors  of  terrorism,  and are  subject to U.S.  economic
          sanctions and export  controls.  Please  describe to us the nature and
          extent of your past,  current,  and  anticipated  contacts  with Iran,
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Cecilia Blye, Esq.
Securities and Exchange Commission
November 13, 2009
Page 2

          Syria and Cuba,  whether through  affiliates,  distributors,  or other
          direct or indirect  arrangements.  Your response  should  describe any
          services you have provided into those  countries,  and any agreements,
          commercial  arrangements,  or  other  contacts  you  have had with the
          governments  of  those  countries  or  entities  controlled  by  those
          governments.

     The limited  activities that the Company has engaged in that are associated
with Iran and Syria are described below. The Company does not have any direct or
indirect contacts with Cuba. To put the activities in Iran and Syria in context,
the Company's overall revenues in 2008 were approximately  $12.3 billion. To the
best of our knowledge,  no U.S.  persons  (including  U.S.  citizens,  permanent
residents,  individuals or entities physically located in the U.S., and branches
and subsidiaries of U.S. corporations) are involved in these activities.

     The discussion below is organized by principal operating unit.

     JWT
     ---

     The Company indirectly owns 31.08% of JWT Limited Liability (formerly known
as J. Walter Thompson Damascus, d/b/a Tihama al Mona Damascus), a Syrian company
("JWT LL"). JWT LL provides  advertising  services to clients in Syria. JWT LL's
revenues  associated  with these services were  approximately  $631,000 in 2006,
$523,000 in 2007 and  $726,000 in 2008.  The  Company's  proportionate  share of
these revenues  would be  approximately  $196,115 in 2006,  $162,548 in 2007 and
$225,641 in 2008;  however,  dividends actually received by the Company were nil
in 2006, $105,000 in 2007 and $101,000 in 2008.

     JWT does not have any assets,  employees or operations in Iran. However, in
order to service  certain  clients with  business in Iran JWT LLC, a United Arab
Emirates company,  obtains some services from a local agency called Darvaag. JWT
LLC bills the clients on behalf of Darvaag but earns no revenues from  Darvaag's
work. There is no standing agreement between JWT LLC and Darvaag.

     Ogilvy & Mather Worldwide ("Ogilvy")
     ------------------------------------

     The Company owns a minority  interest (40%) in Memac Holding Inc., a Panama
company,  which, in turn, owns a minority  interest (49%) in Memac Ogilvy Droubi
("Droubi"),  a Syrian company that commenced  operations in August of this year.
Therefore, the Company's effective interest in Droubi is only 19.6%. The Company
has no board  representation in Droubi.  Droubi provides advertising services to
clients in Syria.  Droubi's revenues associated with these services are expected
to be  approximately  $160,000 in 2009.  The Company's  proportionate  shares of
these revenues would be approximately $31,360.

     The Kantar Group ("Kantar")
     ---------------------------

     Certain  units  of  the  Company's  Information,  Insight  and  Consultancy
segment,  managed under the umbrella of Kantar,  perform services for clients in
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Cecilia Blye, Esq.
Securities and Exchange Commission
November 13, 2009
Page 3

Iran and Syria.  For such  purposes,  these  companies,  including  AMRB and TNS
Middle East & Africa Ltd. ("TNS MEA"),  subcontract the fieldwork to third party
agencies.  AMRB's  revenues  associated  with these services were  approximately
$136,800 in 2006,  $122,700 in 2007, $49,000 in 2008, and a total of $400,000 in
the first three  quarters  of 2009.  TNS,  which was  acquired by the Company in
October 2008,  earned revenues of approximately  $1,400,000 in 2008 and $950,000
in the first nine months of 2009 for these  services  in Iran and Syria.  Of the
amounts   earned  in  2008,   TNS  MEA  paid  out   approximately   $590,000  to
subcontractors.  In addition,  BMRB International,  an affiliate of the Company,
has  granted  an Iranian  company  the right to use BRMB's  Target  Group  Index
materials  in Iran and has  granted  another  Iranian  company  the right to use
BRMB's  Publisher Tool Kit software in Iran. The revenue  associated  with these
license agreements is approximately $40,000 per year.

     Hill & Knowlton
     ---------------

     In July and August  2009,  Hill & Knowlton  Belgium,  an  affiliate  of the
Company,  provided  services in connection  with a small project  (approximately
$12,000) to the subsidiary in the United Kingdom of Melli Bank, an Iranian state
owned bank.

     Grey
     ----

     Grey does not have any assets, employees or operations in Iran. However, in
order to service a European client with business in Iran, Grey Worldwide  Middle
East Network  Sarl ("Grey  MENS"),  an  affiliate  of the Company,  obtains some
services  from a local agency called  Eshareh  Advertising  Agency  ("Eshareh").
Eshareh purchases media space on behalf of Grey MENS for the client.  Grey MENS'
revenues  associated  with these  services were  approximately  $41,000 in 2006,
$85,000 in 2007 and $100,000 in 2008.

     GroupM
     ------

     The Company owns a minority interest (49.12%) in MEC (Mediaedge:cia) FZ LLC
("MEC"),  which books media space in Syria for some of its international clients
through a local agency called  Intermarkets  Advertising  LLC  ("Intermarkets").
Intermarkets  sometimes  books media space outside Syria through MEC for some of
its  own  clients.   MEC's   revenues   associated   with  these  services  were
approximately  $7,600 in 2006, $8,500 in 2007, $5,200 in 2008 and $6,200 for the
first nine months of 2009. The Company's  proportionate  share of these revenues
would be approximately $3,733 in 2006, $4,175 in 2007, $2,554 in 2008 and $3,045
for the first nine months of 2009.

     MEC has also  booked  media  space  in Iran  for some of its  international
clients through a local agency called Hadaf Nihai Co. MEC's revenues  associated
with these  services  were  approximately  $10,500 in 2006 and  $14,200 in 2007;
revenues  associated  with these  services  were nil in 2008 and the first three
quarters of 2009. The Company's  proportionate  share of these revenues would be
approximately $5,158 in 2006 and $6,975 in 2007.
<PAGE>
Cecilia Blye, Esq.
Securities and Exchange Commission
November 13, 2009
Page 4

     2.   Please discuss the  materiality of your contacts with Iran,  Syria and
          Cuba, and whether those contacts constitute a material investment risk
          for  your  security  holders.   You  should  address   materiality  in
          quantitative  terms,  including the approximate  dollar amounts of any
          associated revenues, assets, and liabilities for the last three fiscal
          years and any subsequent period. Also, address materiality in terms of
          qualitative factors that a reasonable investor would deem important in
          making an  investment  decision,  including  the  potential  impact of
          corporate  activities upon a company's  reputation and share value. As
          you  may  be  aware,   various   state  and   municipal   governments,
          universities,  and other investors have proposed or adopted divestment
          or similar  initiatives  regarding  investment  in  companies  that do
          business  with state sponsor of terrorism.  You  materiality  analysis
          should  address  the  potential  impact  of  the  investor   sentiment
          evidenced  by  such  actions   directed  toward  companies  that  have
          operations associated with Iran, Syria and Cuba.

     The Company  does not  believe  that its  contacts  with Iran and Syria are
material  to  its  business.  From a  quantitative  perspective,  the  Company's
contacts  with  Iran and Syria  are  negligible.  Its  aggregate  2008  revenues
associated  with  contacts with these two  countries  amounted to  approximately
$1,400,000, or less than 0.015% of the Company's overall 2008 revenues. As noted
above, the Company does not have any contacts with Cuba.

     Given the quantitative  insignificance of the contacts described above, and
given that the contacts are focused  exclusively  on the  provision of marketing
communications services on behalf of multinational clients, the Company does not
believe that its contacts with Iran and Syria pose any  investment  risk for its
security  holders  from a  qualitative  perspective,  including  any  risk  of a
potential material adverse impact on the Company's reputation and share value.

                                     * * * *

     On behalf of the Company we acknowledge that:

     o    the  Company is  responsible  for the  adequacy  and  accuracy  of the
          disclosure  in its annual  reports on Form 20-F;
     o    staff  comments or changes to disclosure in response to staff comments
          do not foreclose the Commission from taking any action with respect to
          the  annual  reports on Form 20-F;  and
     o    the  Company  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.

<PAGE>
Cecilia Blye, Esq.
Securities and Exchange Commission
November 13, 2009
Page 5

     Please do not hesitate to contact the  undersigned at (212) 468-4944 if you
have any further comments or questions.

                                        Very truly yours,

                                        /s/ Ralph W. Norton
                                        Ralph W. Norton

cc:     Paul W.G. Richardson
        Mark Povey, Esq.
        Firouzeh Bahrampour, Esq.
        Curt Myers, Esq.
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