SecProbe.io

September 28, 2010

Justin D. Benincasa,
Chief Financial Officer and Treasurer Atlantic Tel-Network, Inc 10 Derby Square Salem, MA 01970

Re: Atlantic Tel-Network, Inc.
Form 10-K for the fiscal year ended December 31, 2009
Filed March 16, 2010 File No. 1-12593

Dear Mr. Benincasa:

 We have reviewed your filing and have the following comments.  Please provide us with
the requested information so we may better understand your disclosure.

Please respond to this letter within te n business days by providing the requested
information or by advising us when you will provide the requested response.  If you do not believe our comments apply to your facts and circum stances, please tell us w hy in your response.
 After reviewing the information you provide in response to these comments, we may
have additional comments.
Form 10-K for the year ended December 31, 2009

Item 7 – Management’s Discussion and Analysis of Financial Condition and Results of
Operations
 Critical Accounting Estimates, page 58

 1. We note your disclosure that to assess rec overability of the value of your FCC licenses
you use the market approach.  Tell us why you believe the market approach is an
appropriate methodology to value the FCC licen ses in view of the limited number of
transactions, the differences in the s
pectrum bands, permitted uses, propagation
characteristics, competition, geographic and demographic markets, among others.  Further tell
us whether the fair value determined under the market approach would be materially
different from the fair value determined  under the Greenfield Cash Flow Valuation
Model (“Greenfield Model”).

Justin D. Benincasa, CFO and Treasurer Atlantic Tel-Network, Inc
September 28, 2010 Page 2    Form 10-Q for the period ended June 30, 2010

 Note 4- Acquisitions, page 9

 2. We note that you have recorded the net ga in on bargain purchase in the amount of
approximately $27 million.  In order for us to better understand about the amount of the recorded bargain gain, please tell us in suffi cient detail, the valuation methodologies used
to value each of the assets acquired.

• Please tell us how you fair valued the property, plant and equipment, and each of the
identifiable intangible assets, i.e., the licen ses, trade name and customer relationships.

• Specifically tell us about th e valuation methodology used to value the licenses and
describe
the method you used to isolate the cash flows associated with the intangible
asset.
 • Tell us if there is any likely hood of the Co mpany revising or eliminating the bargain
purchase gain in future.

Your response should specifi cally address paragraph 4 of  ASC 805-30-25. We may have
further comments after re view of your response.

Please file all correspondence over EDGAR.  We urge all persons who are responsible
for the accuracy and adequacy of the disclosure in  the filing to be certain  that the filing includes
the information the Securities Exchange Act of 1934 and all applicable Exchange Act rules
require.  Since the company and its management are in possession of a ll facts relating to a
company’s disclosure, they are responsible for the accuracy and adequacy of  the disclosures they
have made.                In responding to our comments, please provide a written statement from the company
acknowledging that:
• the company is responsible for the adequacy and accuracy of the disclo sure in the filing;

• staff comments or changes to disclosure in response to staff comments do not foreclose
the Commission from taking any action with respect to the filing; and

• the company may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federa l securities laws of  the United States.

  Justin D. Benincasa, CFO and Treasurer Atlantic Tel-Network, Inc
September 28, 2010 Page 3
 You may contact Christine Adams, Staff Accountant, at (202) 551-3363 or Ivette Leon,
Assistant Chief Accountant, at  (202) 551-3351 if you have questi ons regarding comments on the
financial statements and related matters.  Plea se contact Brandon Hill at (202) 551-3268 or me at
(202) 551-3810 with any other questions.
Sincerely,

Larry Spirgel Assistant Director