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CORRESP
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August 4, 2005

BY EDGAR

Larry
Spirgel

Assistant
Director

Division
of Corporation Finance

United
States Securities and Exchange Commission

100 F Street, NE

Washington,
DC  20549

  RE:

  ClearComm, L.P.

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

  Form 10-Q for the period ended March 31, 2005

  File No. 0-28362

Dear
Mr. Spirgel:

On behalf of our client, ClearComm, L.P. (the “Partnership”),
we are responding to the comments of the staff of the Securities and Exchange
Commission (the “Commission”) as set forth in your letter dated July 12,
2005 to Mr. Javier O. Lamoso, President of the Partnership’s general
partner, with respect to (i) the Partnership’s Form 10-K/A for the
fiscal year ended December 31, 2004, (ii) Form 10-Q for the
period ended March 31, 2005, (iii) the supplemental response letters
dated June 1, 2005, (iv) and the supplemental letter dated July 27,
2005.  The original Form 10-K was
filed with the Commission on March 29, 2005, the Form 10-K/A was
filed on June 1, 2005 and the Form 10-K/A (Amendment No. 2) was
filed on July 27, 2005.

As agreed during our telephone conversation yesterday
with Ivette Leon Assistant to Chief Accountant, we are enclosing supplemental
comments in connection with Item 2 of your July 12, 2005 letter regarding the
Partnership’s inventory accounting policies. We have provided below the text of
the comment made in Item 2 of your letter, and the Partnership’s supplemental response
to that comment.  The heading and
numbered paragraph below correspond to the heading and numbered paragraph in
your letter.

Notes to consolidated financial statements

Note 3 – Significant accounting policies

(h) Inventories, page 30

Please refer to your response to comment No. 6.  We believe that the change in accounting method
for the loss on the sale of handsets to customers is not appropriate.  The fact that you sell the handsets in
connection with a service contract at a loss does not mean that the handsets
cannot be sold over the cost of the unit.
It appears that the handset subsidy is a marketing strategy to obtain
new customers.  Therefore, we believe
that you should continue with your accounting policy before January 1,
2003 and recognize the loss on the sale of the handsets at the time of the
sale.  Please revise or advise.

Partnership’s Response:  The
Partnership changed its accounting policy in 2003  regarding valuation of telephone handsets in inventory in
recognition of the realities of the prevailing industry practices.  These practices dictate that the only way to conduct
a competitive business in a six-carrier market is for the Partnership, like all
of its competitors, to offer its handsets at a price significantly less than
the landed purchase price of the handset.
In 2002, on the sale of a handset, the Partnership realized an average
of 45.3% of its cost of each handset; during the first six months of 2005, the
realization is approximately 23% of cost. There
is no market for the sale of the Partnership’s purchased handsets over the cost
of the unit.  In fact, during 2004, only
8.9% of total handsets were sold at cost, and these

PMB 159

ClearComm, L.P.

PO Box 11850

San Juan, PR 00922-1850

Tel. 787-810-5757, ext. 3020

Fax 787-774-5058

www.clearcommlp.com

sales were
exclusively made to existing subscribers who in most cases wanted to upgrade
their handset or were replacing a lost or damaged handset.

In fact, at the time the change in accounting policy
was implemented in 2003, the Partnership and its auditors researched other
registrants to determine if such inventory convention was being followed. We
found that other wireless companies (including Centennial Communications Corp,
the largest wireless company in Puerto Rico) were using a similar approach in
their SEC filings. Centennial, for example, refers to this accounting treatment
as “Reserve for Obsolescence”.

In order to state the Partnership’s inventory of
handsets at the lower of cost or market, where market is defined as net
realizable value, it seems that the Partnership must reduce its inventory to
its estimated sales price to new subscribers taking into consideration current
as well as existing pricing practices which has a similar effect to recording
an inventory reserve for obsolescence.  Accordingly,
since December 31, 2003, the Partnership has relied on this methodology in
pricing its inventory, and we continue to believe that this methodology is consistent
with the correct accounting principle applicable to the pricing of handsets in
the Partnership’s inventory.

We again desire to emphasize that our approach
follows ARB 43, which reads as follows:

ARB 43 – Inventory Pricing –
[W] hen the utility of the goods in the
ordinary course of business is no       longer
as great as their cost, a departure from the cost principle of measuring the
inventory is required. Whether the cause is obsolescence, physical
deterioration, changes in price level, or any other, the difference should
be recognized by a charge to income in the current period. This is
accomplished by stating the goods at a lower level designated as market (emphasis
added).

Before the implementation in 2003 of the revised convention
for inventory pricing the Partnership’s management realized that because its
handsets could not be sold over cost the inherent loss in the inventory of
handsets would result in an overstatement of the Partnership’s assets.  In response, the Partnership (i) changed
its convention for inventory pricing to record inventory losses in the current
period as required under ARB 43 and (ii) began the process of reducing its
handset inventory as illustrated in the following table:

  Number

  Total

  Average

  of handsets

  Cost of

  Unit

  As of December 31,

  in inventory

  handsets

  Cost

  2002

  72,811

  $

  10,036,851

  $

  138

  2003

  64,928

  $

  8,386,968

  $

  129

  2004

  32,749

  $

  4,341,975

  $

  133

  As of
  June 30, 2005

  21,850

  $

  3,200,000

  $

  146

In addition, this revised convention has created an
incentive for the Partnership to improved control over amounts invested in the
inventory of handsets.  As to the effect
of this revised convention on net income (loss) and partners’ (deficiency), the
following statistics are illustrative of the immateriality of the change:

  ($ millions)

  2003

  2004

  Reported Net (loss)

  (28.7

  )

  (27.8

  )

  Loss before change

  in method of inventory

  pricing

  (24.0

  )

  (29.4

  )

  Inventory reserve

  provision (reversal)

  4.7

  (1.6

  )

  Percentage of reported loss

  16.38

  %

  5.76

  %

  Partner’s (deficiency)

  as reported

  (111.30

  )

  (139.10

  )

  Partner’s (deficiency)

  Without pricing change

  (106.60

  )

  (136.00

  )

  Percentage of reported

  Partner’ (deficiency)

  95.78

  %

  97.77

  %

Finally, we respectfully request and opportunity to
discuss the foregoing with you and your staff by teleconference or in person at
your earliest possible convenience.

  Sincerely,

  /s/Edileen  Salicrup

  Edileen Salicrup

  cc:

  Javier O. Lamoso

  Aaron Ghais