SecProbe.io

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549

       DIVISION OF
CORPORATION FINANCE

        July 15, 2009           Mr. Robert D. Daleo Chief Financial Officer  Thomson Reuters 3 Times Square New York, NY 10036   Re: Thomson Reuters Corporation
Form 40-F for the fiscal year ended December 31, 2008
Thomson Reuters PLC Form 20-F for the fiscal year ended December 31, 2008
  File No. 01-31349
Dear Mr. Daleo:
  We have reviewed the above referenced filings and have the following comments.
Unless otherwise indicated, we believe you shoul d revise future filings in response to
these comments.  If you disagree, we will cons ider your explanation as to why a revision
is unnecessary.  Please be as detailed as necessary in your explanation.     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 filings.  We look forward to working with you in thes e respects and welcome any questions.  Feel
free to call us at the telephone numbers  listed at the end of this letter.

Please file your response to our comment s via EDGAR, under the label “corresp,”
within ten business days from the date of this letter.

Form 40-F and Form 20-F For the fi scal year ended December 31, 2008

Management’s Discussion and Analysis
Results of Operations, page 23

1. Please revise to separately discuss and analyze cost of sa les (COS) and selling,
marketing, general and administrative expens es (S, M, G&A).  In this regard, we
believe it would be useful to investors understanding of your results of operations
to better understand the nature and am ounts of major components of expenses
within these categories, such as labor,  technology costs, information and licensing
costs, or other sub-categories, as appropriate.

Thomson Reuters
July 15, 2009
Page 2 of 3
2. Please ensure that you quantify material fact ors to which variances are attributed.
For example, on page 27 you state that revenues from existing businesses increased in 2008 as a result of higher transaction revenues and higher revenues from Thomson ONE products but you do not  quantify these factors.  In addition,
please ensure that you analyze the underlyi ng reason for the factors.  For example,
if known, explain why transact ion revenues were higher.

3. We note from your footnotes that you unde rtake a significant number of hedging
transactions for currencies a nd interest rates, among othe r items.  However, it is
not clear what aggregate effect these transactions have on your results of
operations from period to period.  To the ex tent available, please tell us what
aggregate impact hedging and derivative tran sactions have had on your results of
operations for each of the years in th e three year period ending December 31,
2008.
 Note 3:  Acquisition of Reuters Group PLC, page 73

4. We note that approximately $6.7 billion of  the purchase price of Reuters Group
PLC was allocated to identifiable intangi ble assets such as trade names and
customer relationships.  Based upon the di scussion provided on page 10 it appears
that intangible assets other than those iden tified exist in the business.  Please tell
us what consideration was given to allocating the purchase price to these
additional intangibles.

Note 15:  Segment Information, page 103

5. We note that the operations of former Reuters Group PLC have been combined into the Markets reportable segment a lthough these operations were previously
presented as four reportable segments prior to the acquisition.  Pl ease tell us what
consideration was given to continuing to report these as separate reportable
segments.

********

  We urge all persons who are responsi ble for the accuracy an d adequacy of the
disclosure in your filings to be certain that  the filings include all information required
under the Securities Exchange Act of 1934 and that they have provided all information
investors require for an informed invest ment decision.  Since the company and its
management are in possession of all facts re lating to a company’s disclosure, they are
responsible for the accuracy and adequacy of the disclosures they have made.
  In connection with responding to our comments, please provide, in writing, a statement from the company acknowledging that:

Thomson Reuters
July 15, 2009 Page 3 of 3           ‚ the company is responsible for the adequacy  and accuracy of the disclosure in its
filings;
‚ staff comments or changes to disclosure  in response to staff comments do not
foreclose the Commission from taking any action with respect to the filings; 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 advise d that the Division of Enfo rcement has access to all
information you provide to the staff of the Divi sion of Corporation Fi nance in our review
of your filings or in response to our comments on your filings.

 You may contact Theresa Messinese at 202-551-3307 or the undersigned at 202-
551-3380 with any other questions.
Sincerely,

Lyn Shenk
Branch Chief