SecProbe.io

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Mail Stop 0407
      						May 17, 2005

Via U.S. Mail and Fax (787) 774-5058

Mr. Javier O. Lamoso, President
ClearComm, L.P.
City View Plaza, Suite 700
No. 48 of Road 165
Guaynabo, Puerto Rico 00968

	RE:	ClearComm, L.P.
      Form 10-K for the fiscal year ended December 31, 2004
		File No. 0-28362

Dear Mr. Lamoso:

      We have reviewed the above referenced filing and have the
following comments.  We have limited our review to only your
financial statements and related disclosures and will make no
further
review of your documents.  As such, all persons who are
responsible
for the adequacy and accuracy of the disclosure are urged to be
certain that they have included all information required pursuant
to
the Securities Exchange Act of 1934.  Please address the following
comments in the amended filing.  If you disagree, we will consider
your explanation as to why our comment is inapplicable or a future
revision is unnecessary.  Please be as detailed as necessary in
your
explanation.  In some of our comments, we may ask you to provide
us
with supplemental information so that we may better understand
your
disclosure.  After reviewing this information, we may or may not
raise additional comments.

	Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.

ClearComm, L.P.
May 17, 2005
Page 2

Form 10-K for the year ended December 31, 2004

Item 6 - Selected financial data, page 10

1. Revise to include selected financial data for each of the last
five fiscal years of the registrant in accordance with Item 301 of
Regulation S-K.

Report of independent public accountants, page 22

2. Ask your auditors to revise their report for the following:

* to make reference to the Standards of the Public Company
Accounting
Oversight Board in accordance with auditing standard no. 1 of the
PCAOB;  and,
* to include a signed audit report.

Statements of operations, page 24

3. Revise the statements of operations to include depreciation and
amortization within operating expenses.  Also, if costs and
expenses
applicable to sales and revenue exclude depreciation and
amortization
directly applicable to the generation of revenue, then revise your
presentation to comply with SAB 11:B.

4. We note that you paid commissions to salesmen and dealers.
Provide us more details about the different types of commissions.
Tell us the consideration given to EITF 01-9 in the classification
of
these commissions as operating expenses rather than a reduction of
revenues.

5. Revise to show the Minority interest in income (loss) of
NewComm
on the face of the income statement in accordance with Rule 5-03
(12)
of Regulation S-X.

Note 3 - Significant accounting policies

      (h) Inventories, page 30

6. Explain to us the new method to account for the loss on sale of
handsets.  To help us understand your accounting, please provide
us
the related journal entries.

ClearComm, L.P.
May 17, 2005
Page 3

Item 9A. Control and procedures, page 55

7. We note in last sentence that "There have been no significant
changes in the Company`s internal controls or in other factors
that
could significantly affect internal controls, subsequent to the
date
the President and Chief Officer completed their evaluations."
Please confirm in writing whether there was any change in your
internal control over financial reporting identified in connection
with an evaluation thereof that occurred during the period covered
by
the above report that has materially affected, or is reasonably
likely to materially affect, your internal control over financial
reporting.  Please see Item 308(c) of Regulation S-K.  Please also
revise your future filings accordingly.

	In connection with responding to our comment, please provide,
in
writing, a statement from the company acknowledging that

* the company is responsible for the adequacy and accuracy of the
disclosure in the filings;
* staff comments or changes to disclosure in response to staff
comments in the filings reviewed by the staff 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
federal securities laws of the United States.

      In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in our review of your filing or in
response to our comments on your filing.

      Please respond to these comments within 10 business days or
tell us when you will provide us with a response.  Please furnish
a
letter that keys your responses to our comments and provides any
requested supplemental information.  Please file your response
letter
on EDGAR.  You may contact Gopal Dharia, Staff Accountant, at
(202)
551-3353 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,

							Larry Spirgel
							Assistant Director

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