SecProbe.io

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<TYPE>LETTER
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Mail Stop 3561

      December 21, 2005

Via U.S. Mail and Fax (787-282-0958)

Mr. Adail Ortiz
Vice President and Chief Financial Officer
Telecomunicaciones de Puerto Rico, Inc.
1515 FD Roosevelt Ave.
Guaynabo, Puerto Rico 00968

	RE:	Telecomunicaciones de Puerto Rico, Inc.
      Form 10-K for the Year ended December 31, 2004
		Filed March 31, 2005
		File No. 333-85503

Dear Mr. Ortiz:

      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 address the following comments
in
future filings.  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
information so 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 any other aspect
of
our review.  Feel free to call us at the telephone numbers listed
at
the end of this letter.

Form 10-K for the Year Ended December 31, 2004

Consolidated statement of operations, page 43
1. Revise your presentation of operating costs and expenses to
comply
with Rule 5-03 of Regulation S-X (i.e. costs of revenues, S, G&A,
etc.)

Note 2. Summary of Significant Accounting Policies

Revenue Recognition, page 47
2. Addressing any relevant accounting literature supplementally
tell
us in detail how you account for:

a. the loss on sales of handsets;

b. the sales of service and handsets through your kiosks and
stores;

c. the sales of service and handsets through dealers and agent
outlets.
3. We note that you defer activation and installation revenues and
certain related costs for both wireline and wireless. Confirm, if
it
is true, that you deferred costs to the extent of deferred
revenues.
Revise your disclosures in future filings.
Property, Plant and Equipment and Depreciation, page 47

4. Explain to us your accounting for the depreciation expenses
under
the composite group remaining life and the straight-line composite
rates.  Advise us the various items with their respective lives
included in each group such as `Outside Plant` and `Central Office
and Transmission Equipment`. Also, tell us your basis in using
these
depreciation methods.

*    *    *    *

      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 information.  Detailed letters greatly facilitate our
review.  Please understand that we may have additional comments
after
reviewing your responses to our comments.

	We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings reviewed by the staff to
be
certain that they have provided all information investors require
for
an informed decision.  Since the company 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 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 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 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 filings or
in
response to our comments on your filings.

      You may contact Andrew Mew, Senior Staff Accountant, at
(202)
551-3377 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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Telecomunicaciones de Puerto Rico, Inc.
December 21, 2005
Page 1

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