SecProbe.io

November  25, 2013

Via E -mail
Mr. Justin D. Benincasa
Chief Financial Officer
Atlantic Tele -Network , Inc.
600 Cummings Center
Beverly, MA

Re: Atlantic Tele -Network,  Inc.
Form 10-K for the Year Ended December  31, 2012
Filed March 18 , 2013
File No. 00 1-12593

Dear Mr. Justin :

 We have reviewed your filing and have the following comments.  We have limited our
review to only your financial statements and related disclosures and do not intend to expand our
review to other portions of your documents.  Please comply with the following comments in
future filings.  Confirm in writing that you will do so and explain to us how you intend to
comply.  In some of our comments, we may ask you to provide us with information so we may
better understand your disclosure.

Please respond to this letter within ten business days by providing the requested
information  or by advising us when you will provide the requested response.   If you do not
believ e our comment s apply to your facts and circumstances, please tell us why in your response.

After reviewing the information you provide in response to these comment s, we may
have  additional comments.

Form 10-K for the Year Ended December  31, 2012

Results of Operations, page 39

1. We note your disclosure on page 42, which states that, “Termination and access fees
decreased by $48.8  million, or 24% from $204.6  million for the year ended December  31,
2011 to $155.8  million for the year ended December  31, 2012. The decrease was
primarily the result of a reduction in roaming expenses, decreased customer bad debt
expense, and the elimination of duplicate costs from the Alltel Transition in our U.S.
Wireless segment. These decreases were partially offset by an increase in data usage

Mr. Benincasa
Atlantic Tele -Network , Inc.
November  25, 2013
Page 2

 volume which increases "backhaul" costs as well as an increase in circuit costs within our
U.S. Wireline segment as our network continues to expand.”  When more than one factor
is the cause of a fluctuation in a material line item , please quantify each significant  factor
that affected the  change .
Comment OK. IL

2.  Summary of Significant Accounting Policies, page F -9

2. You disclose on pages 38 -41 that you receive d several different types of grants from
different sources.  Please di sclose your accounting policy for the various types of grants
and/or stimulus received from government agencies.

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 compa ny and its management are
in possession of all 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 disclosure in the filing;

 staff comments or changes to disclosure in response to staff comments do not foreclose
the Commission from taking any action wi th 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 federal securities laws of the United States.

You may contact Inessa Kessman , Senior Staff Accounta nt, at 202-551-3371 or Ivette
Leon , Assistant Chief Accountant , at 202-551-3351 if you have questions regarding comments
on the financial statements and related matters.  Please contact me at  202-551-3810  with any
other questions.

Sincerely,

 /s/ Terry French for

Larry Spirgel
Assistant Director