SecProbe.io

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 1
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 CORRESP

 VIA EDGAR and E-MAIL
 April 1, 2025 Division of Corporation Finance
 Office of Manufacturing U.S. Securities and Exchange Commission
 100 F Street, N.E. Washington, DC 20549

 Re:
 Thomson Reuters Corporation
 TR Finance LLC Thomson
Reuters Applications Inc. Thomson Reuters (Tax & Accounting) Inc.
 West Publishing Corporation
 Registration Statements on Form F-10 (File
 No. 333-285907) and Form F-3 (File Nos. 333-285927,
 333-285927-01, 333-285927-02 and 333-285927-03) To Whom It May Concern:
 On behalf of Thomson Reuters Corporation, a corporation incorporated in the Province of Ontario, Canada, TR Finance LLC, a Delaware limited liability company,
Thomson Reuters Applications Inc., a corporation incorporated under the laws of the State of Delaware, Thomson Reuters (Tax & Accounting) Inc., a corporation incorporated under the laws of the State of Texas, and West Publishing
Corporation, a corporation incorporated under the laws of the State of Minnesota (collectively, the “ Registrants ”), enclosed is the final receipt issued by the Ontario Securities Commission with respect to the final base shelf
prospectus contained in the Registrants’ Registration Statements on Form F-10 (File No. 333-285907) and Form F-3 (File
Nos. 333-285927, 333-285927-01, 333-285927-02 and
 333-285927-03). We hereby request that the U.S. Securities and Exchange Commission declare the Registration Statements effective as of 4:30 p.m., New York time, on
Thursday, April 3, 2025, or as soon as possible thereafter. If the Staff has any questions, please contact Christopher R. Bornhorst, Esq. of Torys
LLP at cbornhorst@torys.com or (212) 880-6047.

 Sincerely,

 THOMSON REUTERS CORPORATION

 By:

 /s/ Jennifer Ruddick

 Name: Jennifer Ruddick

 Title: Deputy Company Secretary

 TR FINANCE LLC

 By:

 /s/ Richard Napolitano

 Name: Richard Napolitano

 Title: Chief Financial Officer

 THOMSON REUTERS APPLICATIONS INC.

 By:

 /s/ Richard Napolitano

 Name: Richard Napolitano

 Title: Vice President & Assistant Secretary

 THOMSON REUTERS (TAX & ACCOUNTING) INC.

 By:

 /s/ Richard Napolitano

 Name: Richard Napolitano

 Title: Vice President & Assistant Secretary

 WEST PUBLISHING CORPORATION

 By:

 /s/ Richard Napolitano

 Name: Richard Napolitano

 Title: Vice President & Assistant Secretary

 Ontario

 Commission des

 22nd Floor

 22e étage

 Securities

 valeurs mobilières

 20 Queen Street West

 20, rue queen ouest

 Commission

 de l’Ontario

 Toronto ON M5H 3S8

 Toronto ON M5H 3S8

 RECEIPT Thomson Reuters
Corporation TR Finance LLC This
is the receipt of the Ontario Securities Commission for the Short Form Base Shelf Prospectus of the above Issuer dated March 31, 2025 (the prospectus).
 The prospectus has been filed under Multilateral Instrument 11-102 Passport System in Alberta, British
Columbia, Manitoba, New Brunswick, Newfoundland and Labrador, Nova Scotia, Prince Edward Island, Quebec, Saskatchewan . A receipt for the prospectus is deemed to be issued by the regulator in each of those jurisdictions, if the conditions of the
Instrument have been satisfied. March 31, 2025

 /s/ Winnie Sanjoto

 Winnie Sanjoto

 Senior Vice President, Corporate Finance Division

 Filing No.

 06254242, 06254253

 Ontario

 Commission des

 22nd Floor

 22e étage

 Securities

 valeurs mobilières

 20 Queen Street West

 20, rue queen ouest

 Commission

 de l’Ontario

 Toronto ON M5H 3S8

 Toronto ON M5H 3S8

 RECEIPT TR Finance LLC
 Thomson Reuters Corporation This
is the receipt of the Ontario Securities Commission for the Short Form Base Shelf Prospectus of the above Issuer dated March 31, 2025 (the prospectus).
 The prospectus has been filed under Multilateral Instrument 11-102 Passport System in Alberta, British
Columbia, Manitoba, New Brunswick, Newfoundland and Labrador, Nova Scotia, Prince Edward Island, Quebec, Saskatchewan . A receipt for the prospectus is deemed to be issued by the regulator in each of those jurisdictions, if the conditions of the
Instrument have been satisfied. March 31, 2025

 /s/ Winnie Sanjoto

 Winnie Sanjoto

 Senior Vice President, Corporate Finance Division

 Filing No.

 06254253, 06254242

CORRESP
1
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CORRESP

 VIA EDGAR and E-MAIL

June 20, 2024

 Division of Corporation Finance

Office of Manufacturing

 U.S. Securities and Exchange Commission

 100 F Street, N.E.

 Washington, DC 20549

Re:
 Thomson Reuters Corporation

TR Finance LLC

 Thomson
Reuters Applications Inc.

 Thomson Reuters (Tax & Accounting) Inc.

West Publishing Corporation

Registration Statement on Form F-10 (File
No. 333-279991) and Form F-3 (File Nos. 333-280007,
333-280007-01, 333-280007-02 and 333-280007-03)

 To Whom It May Concern:

On behalf of Thomson Reuters Corporation, a corporation incorporated in the Province of Ontario, Canada, TR Finance LLC, a Delaware limited liability company,
Thomson Reuters Applications Inc., a corporation incorporated under the laws of the State of Delaware, Thomson Reuters (Tax & Accounting) Inc., a corporation incorporated under the laws of the State of Texas, and West Publishing
Corporation, a corporation incorporated under the laws of the State of Minnesota (collectively, the “Registrants”), enclosed is the final receipt issued by the Ontario Securities Commission with respect to the final base shelf
prospectus contained in the Registrants’ Registration Statement on Form F-10 (File No. 333-279991) and Form F-3 (File
Nos. 333-280007, 333-280007-01, 333-280007-02 and
333-280007-03). I hereby request that the U.S. Securities and Exchange Commission declare the Registration Statement effective as of 9:30 a.m., New York time, on
June 24, 2024, or as soon as possible thereafter.

 If the Staff has any questions, please contact Christopher R. Bornhorst, Esq. of Torys LLP at
cbornhorst@torys.com or (212) 880-6047.

Sincerely,

THOMSON REUTERS CORPORATION

By:

 /s/ Jennifer Ruddick

Name: Jennifer Ruddick

Title: Deputy Company Secretary

TR FINANCE LLC

By:

 /s/ Linda J. Walker

Name: Linda J. Walker

Title: Chief Financial Officer

THOMSON REUTERS APPLICATIONS INC.

By:

 /s/ Linda J. Walker

Name: Linda J. Walker

Title: Senior Vice President & Assistant Secretary

THOMSON REUTERS (TAX & ACCOUNTING) INC.

By:

 /s/ Linda J. Walker

Name: Linda J. Walker

Title: Vice President & Assistant Secretary

WEST PUBLISHING CORPORATION

By:

 /s/ Linda J. Walker

Name: Linda J. Walker

Title: Vice President & Assistant Secretary

 Ontario

Securities

 Commission

 Commission des

valeurs mobilières

 de l’Ontario

 22nd Floor

20 Queen Street West

Toronto ON M5H 3S8

 22e étage

20, rue queen ouest

Toronto ON M5H 3S8

 RECEIPT

Thomson Reuters Corporation

TR Finance LLC

 This is the receipt of the
Ontario Securities Commission for the Shelf Prospectus of the above Issuer dated June 18, 2024 (the prospectus).

 The prospectus
has been filed under Multilateral Instrument 11-102 Passport System in Alberta, British Columbia, Manitoba, New Brunswick, Newfoundland and Labrador, Nova Scotia, Prince Edward Island, Quebec,
Saskatchewan. A receipt for the prospectus is deemed to be issued by the regulator in each of those jurisdictions, if the conditions of the Instrument have been satisfied.

June 19, 2024

Winnie Sanjoto

Winnie Sanjoto

Senior Vice-President, Corporate Finance

Filing No.    06143568, 06143569

 Ontario

Securities

 Commission

 Commission des

valeurs mobilières

 de l’Ontario

 22nd Floor

20 Queen Street West

Toronto ON M5H 3S8

 22e étage

20, rue queen ouest

Toronto ON M5H 3S8

 RECEIPT

TR Finance LLC

 Thomson
Reuters Corporation

 This is the receipt of the Ontario Securities Commission for the Shelf Prospectus of the above Issuer dated
June 18, 2024 (the prospectus).

 The prospectus has been filed under Multilateral Instrument
11-102 Passport System in Alberta, British Columbia, Manitoba, New Brunswick, Newfoundland and Labrador, Nova Scotia, Prince Edward Island, Quebec, Saskatchewan. A receipt for the prospectus is
deemed to be issued by the regulator in each of those jurisdictions, if the conditions of the Instrument have been satisfied.

 June 19, 2024

 Winnie Sanjoto

Winnie Sanjoto

Senior Vice-President, Corporate Finance

Filing No.    06143569, 06143568

Mail Stop 3561
August  2, 201 7

Deirdre Stanley
Executive Vice President, General Counsel and Secretary
Thomson Reuters Corporation
333 Bay Street Suite 400
Toronto, Ontario M5H 2R2, Canada

Re: Thomson Reuters Corporation
 Form 40-F for Fiscal Y ear Ended December 31 , 2016
Filed March 9, 2017
File No. 001 -31349

Dear Ms. Stanley :

We have completed our review of your filing.  We remind you that the company and its
management are responsible for the accuracy and adequacy of the ir disclosure s, notwithstanding
any review, comments, action or absence of action by the staff .

Sincerely,

 /s/ Lyn Shenk

 Lyn Shenk
Branch Chief
Office of Transportation and Leisure

CORRESP
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CORRESP

 July 12, 2017

VIA EDGAR/CORRESPONDENCE

 Ms. Lyn Shenk

Branch Chief

 Office of Transportation and Leisure

Division of Corporation Finance

 U.S. Securities and Exchange
Commission

 100 F Street, N.E.

 Washington, D.C. 20549

Re:

 Thomson Reuters Corporation

 Form 40-F for
Fiscal Year Ended December 31, 2016

 Filed March 9, 2017

File No. 001-31349

 Dear Ms. Shenk:

 We have
received your letter dated June 27, 2017 related to the above-mentioned filing of Thomson Reuters Corporation (referred to as the “Company” or “we” in this response). With respect to the two items in that letter, we are
providing the following responses. To assist your review, we have included the text of the Staff’s comments below in italics.

 Form 40-F for
Fiscal Year Ended December 31, 2016

 Exhibit 99.1

Notes to Consolidated Financial Statements

Note 22: Deferred Tax, page 133

1.
You disclose you did not recognize deferred tax assets of $1,804 million related to $6,471 million of tax losses carried forward. We note this represents essentially all of the total tax losses carried forward at
December 31, 2016 of $6,516 million. Of the total amount of tax losses for which no deferred tax assets are recognized, you disclose that $4,884 million is attributed to other jurisdictions, the majority of which may be carried forward
indefinitely. Please explain to us the basis for your belief it is not probable that tax losses carried forward will be utilized.

 1

 Company response:

As noted by the Staff, the Company did not recognize deferred tax assets related to $6,471 million of tax losses carried forward as of December 31, 2016.

•

Of this amount, $1,607 million related to Canadian tax losses, which are driven by interest expense that far exceeds the profit generated by our Canadian operations. As such, our Canadian entities do not have a
history or forecasts of taxable profit that would enable utilization of the losses.

•

The remaining amount, which originated in jurisdictions outside of Canada, predominantly related to impairments of investments in various subsidiaries for statutory accounting and tax purposes, most of which may be
carried forward indefinitely. These companies generate minimal or no income except for dividends from other Thomson Reuters subsidiaries. Such income is not taxable and therefore does not provide a source of income to enable utilization of the tax
losses.

 In reaching our determination that it is probable that the tax losses carried forward described above would not be utilized, the
Company applied IAS 12, paragraphs 34-36, in support of our accounting conclusions. Specifically, the entities in question do not have sufficient taxable temporary differences nor convincing evidence of future taxable profitability to support the
future utilization of tax losses. Additionally, the Company did not identify opportunities (as such term is referenced in paragraph 36(d) of IAS 12) to utilize the tax losses. As a result, the Company did not recognize deferred tax assets for these
unused tax losses.

2.
The document titled “Thomson Reuters Economic Data” available on your website identifies the Bank of Sudan, the Central Bank of Syria and the Central Bureau of Statistics, Sudan, as among many Thomson
Reuters Economic Data Sources. Please clarify for us whether you source economic data directly from the Sudanese and Syrian entities you identify, or indirectly. If you source the data indirectly, please tell us whether you source the data through
third-party sources not located in or affiliated with Sudan or Syria. We may have further comment.

 Company response:

The economic data in our products that was derived from the Bank of Sudan, the Central Bank of Syria and the Central Bureau of Statistics, Sudan, was sourced
directly by our company from each organization’s publicly available websites. We did not (directly or indirectly) enter into content license agreements, other commercial arrangements or business transactions with these organizations for this
economic data. No fees or other items of value were paid (directly or indirectly) by our company for the economic data from these sources.

 We provide a
broad and robust range of offerings to financial markets professionals and many of our customers turn to us for global and country-specific data. As part of the informational offerings of our business, we included economic data in our products from
the above-named sources. This data represents an immaterial portion of the information that we make available to our customers, on both a quantitative and qualitative basis.

 2

 As a global organization that operates around the world, we seek to comply with applicable laws, rules and
regulations related to trade embargoes, sanctions and export regulations. Our Code of Business Conduct and Ethics (which applies to all Thomson Reuters employees, directors and officers) specifically addresses the importance of compliance in this
area. Our compliance program includes dedicated resources in our Legal Department, various policies and information that are made available to Thomson Reuters staff on our intranet, screening and training.

***

 Please feel free to contact me at
(203) 539-8448 or linda.walker@tr.com if you have any questions or require any additional information with respect to the foregoing.

 Sincerely,

/s/ Linda J. Walker

 Linda J. Walker

Senior Vice President, Controller & Chief Accounting Officer

cc:

Jim Smith, President & Chief Executive Officer

Stephane Bello, Executive Vice President & Chief Financial Officer

Deirdre Stanley, Executive Vice President, General Counsel & Secretary

Marc Gold, Senior Vice President & Associate General Counsel, Corporate & Securities

Thomson Reuters Audit Committee

Joseph Tort, PricewaterhouseCoopers LLP

Cornell Wright, Torys LLP

 3

Mail Stop 3561
June 27, 201 7

Deirdre Stanley
Executive Vice President , General Counsel  and Secretary
Thomson Reuters Corporation
333 Bay Street Suite 400
Toronto, Ontario M5H 2R2, Canada

Re: Thomson Reuters Corporation
 Form 40-F for Fiscal Y ear Ended December  31, 2016
Filed March  9, 201 7
File No. 001-31349

Dear Ms. Stanley :

We have reviewed your filing an d have the following comments.  In some of our
comments, we may ask you to  provide us with information so we may better understand your
disclosure.

Please respond to these comments  within ten busine ss days by providing the requested
information or advis e us as soon as possible when you will respond.  If you do not believe our
comments apply to your facts and circumstances, please tell us why in your response.

After reviewing your response to these  comments, we may have  additional comments.

Form 40 -F for  Fiscal  Year Ended December 31, 2016

Exhibit 99.1

Notes to Consolidated Financial Statements

Note 22: Deferred Tax, page 133

1. You disclose you did not recognize deferred tax assets of $1,804 million related to $6,471
million of tax losses carried forward.  We note this represents essentially all of the total tax
losses carried forward at December 31, 2016 of $6,516 million.  Of the total amount of tax
losses for which no deferred tax assets are recognized, you disclose that $4,884 million is
attributed to o ther jurisdictions, the majority of which may be carried forward indefinitely.
Please explain to us the basis for your belief it is not probable that tax losses carried forward
will be utilized.

Deirdre Stanley
Thomson Reuters Corporation
June 27, 2017
Page 2

 General

2. The document titled “Thomson Reuters Economic Da ta” available on your website identifies
the Bank of Sudan, the Central Bank of Syria and the Central Bureau of Statistics, Sudan, as
among many Thomson Reuters Economic Data Sources.   Please clarify for us whether you
source economic data directly from th e Sudanese and Syrian entities you identify, or
indirectly.   If you source the data indirectly, please tell us whether you source the data
through third -party sources not located in or affiliated with Sudan or Syria.   We may have
further comment.

We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.

You may contact Patrick Kuhn  at (202) 551 -3308  or Doug Jones at (202) 551 -3309  with
any questions .  You may also call me at (202) 551 -3380.

Sincerely,

 /s/ Lyn Shenk

Lyn Shenk
Branch Chief
Office of Transportation and Leisure

Mail Stop 3561
August  19, 201 5

 Stephane Bello
 Executive Vice President  Finance and Chief Financial Officer
 Thomson Reuters Corporation
 3 Times Square
 New York, NY 10036

Re: Thomson Reuters Corporation
 Form 40-F for Fiscal Y ear Ended December  31, 2014
Filed March  13, 2015
File No. 001 -31349

Dear Mr. Bello :

We have completed our review of your filing.  We remind you that our comments or
changes to disclosure in response to our comments do not foreclose the Commission from taking
any action with respect to the company or 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 securitie s laws of the United States.  We urge all persons who are responsible for the
accuracy and adequacy of the disclosure in the filing  to be certain that the filing  include  the
information the Securities Exchange Act of 1934 and all applicable rules require.

Sincerely,

 /s/ Lyn Shenk

 Lyn Shenk
Branch Chief
Office of Transportation and Leisure

CORRESP
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CORRESP

 July 24, 2015

VIA EDGAR/CORRESPONDENCE

 Mr. Lyn Shenk

Branch Chief

 Division of Corporation Finance

U.S. Securities and Exchange Commission

 100 F Street, N.E.

Washington, D.C. 20549

Re:
Thomson Reuters Corporation

 Form 40-F for Fiscal Year Ended December 31, 2014

Filed March 13, 2015

 File
No. 001-31349

 Dear Mr. Shenk:

 We have received
your comment letter dated July 10, 2015 related to the above-mentioned filing of Thomson Reuters Corporation. With respect to the item in that letter, we are providing the following response. To assist your review, we have included the text of
the comment below in italics.

 Exhibit 99.1

Notes to Consolidated Financial Statements

Note 6: Other operating gains, net, page 96

1.
You disclose that you recorded in 2014 a $931 million gain related to the release of accumulated foreign currency translation adjustments from shareholders’ equity that was triggered by the loss of control of a
subsidiary. So that we may better understand your accounting for this transaction, please tell us the following:

•

The name of the subsidiary for which control was lost;

•

The location of the subsidiary;

•

The nature of the subsidiary’s operations;

•

The form of control before the transaction;

•

The form of control you retained and the subsequent accounting for your investment going forward;

 1

•

Explain how you lost control of the subsidiary through the permanent settlement of an intercompany loan, an apparent related party transaction, and the facts and circumstances leading to the settlement;

•

Cite the accounting literature you relied upon to support your accounting; and

•

Provide the calculation on how you computed the gain.

 Company response:

Staff Request

Response

 Name of the subsidiary for which control was
lost

Thomson Reuters Investments (2002) Ltd. (“TRI 2002”)

 Location of the subsidiary

Domiciled in England prior to disposal

 Nature of the subsidiary’s
operations

A non-trading entity that was previously used largely for intercompany activity

 Form of control before the
transaction

Consolidated subsidiary - 100% indirectly owned by Thomson Reuters Corporation

Form of control retained and subsequent accounting for your investment going forward

TRI 2002 was disposed as part of our simplification program initiative to reduce the number of our subsidiaries. TRI 2002 was considered
disposed upon dissolution and removal from the U.K. Company Register. Loss of control occurred upon disposal. As TRI 2002 no longer exists, there is no retained control and, after reporting the gain on disposal, there is no further
accounting.

 Explain how you lost control of the subsidiary through the permanent settlement of an intercompany loan, an apparent
related party transaction, and the facts and circumstances leading to the settlement

 Thomson Reuters Corporation (the “Company”) is
executing various initiatives as part of a simplification program intended to reduce costs and leverage scale. As part of that program, we are reducing the number of legal entities through which we operate, in order to lower costs and complexity.
TRI 2002 was eliminated as part of this program.

 TRI 2002 was a non-trading entity that did not own any subsidiaries or other investments. The only
significant assets of TRI 2002 were approximately £3.5 billion of intercompany loans receivable due from Thomson Reuters Group Limited (“TRGL”), another consolidated subsidiary of the Company. These loans were established at the time
that we acquired Reuters Group PLC on April 17, 2008 (the “loan inception date”) to form the Company.

 2

 The intercompany loans created a foreign exchange (“FX”) transaction exposure for TRGL, a U.S. dollar
functional currency entity, but there was no FX exposure to TRI 2002, a British pound sterling (“£”) functional currency entity. There was no intent or expectation that TRGL would repay these amounts. Therefore, the intercompany
loans were considered part of the net investment of TRI 2002 and permanent in nature. Accordingly, changes in the value of these loans arising from movements in the USD/£ exchange rate from the loan inception date were recognized directly in
the “other comprehensive income” component of equity in accordance with IAS 21, “The Effects of Changes in Foreign Exchange Rates” (“IAS 21”).

Prior to disposal, the intercompany receivables and payables of TRI 2002 were settled. The net amount was distributed to the shareholders of TRI 2002. We lost
control of TRI 2002 in the fourth quarter of 2014 when it was disposed through dissolution and removal from the U.K. Company Register.

 Upon disposal of
TRI 2002, the accumulated foreign currency translation adjustments (“CTA”) relating to TRI 2002, the most significant of which were the FX gains arising from the intercompany loans to TRGL, were reclassified from the “other
comprehensive income” component of equity to the income statement in accordance with IAS 21.

 Cite the accounting literature you relied upon to
support your accounting

 We relied on IAS 21 as the basis for our accounting up to the date of disposal as well as for the disposal accounting
itself. Our accounting conclusions and applicable literature are summarized below.

 The FX gains and losses arising on the intercompany loans were
recorded in the “other comprehensive income” component of equity from the date they were established, as we had no intent to repay the loans.

•

Paragraph 15 of IAS 21 states that “[a]n item for which settlement is neither planned nor likely to occur in the foreseeable future is, in substance, a part of the entity’s net investment in that foreign
operation”. Paragraph 32 of IAS 21 states that exchange differences arising from these items “shall be recognized initially in other comprehensive income”.

The accumulated CTA, including FX gains arising from the intercompany loans, were reclassified from the “other comprehensive income” component
of equity to the income statement upon disposal of TRI 2002 in Q4 2014.

•

Paragraph 49 of IAS 21 indicates that “[a]n entity may dispose or partially dispose of its interest in a foreign operation through sale, liquidation, repayment of share capital or abandonment of all, or part of,
that entity.”

 3

 We recorded the disposal in accordance with our accounting policy (see note 1 to our 2014 annual consolidated
financial statements), which is consistent with IAS 21 and states the following:

 “Upon loss of control, significant influence or
joint control of the applicable entity, accumulated foreign exchange gains and losses, including those arising from settlement of intercompany loans previously considered permanent in nature, are recycled from accumulated other comprehensive loss to
“Other operating gains, net” within the consolidated income statement.”

 Accordingly, we recycled the accumulated FX amounts upon the
disposal of TRI 2002. Paragraph 48 of IAS 21 refers to reclassifying FX on items “relating” to the disposed entity. This indicates that if neither the loan nor a party to the loan exists, the related FX may no longer be deferred in the
“other comprehensive income” component of equity.

 Provide the calculation on how you computed the gain

In accordance with paragraph 48 of IAS 21, the entire balance of accumulated CTA relating to TRI 2002 was reclassified from the “other comprehensive
income” component of equity to the income statement upon disposal. The accumulated CTA was primarily comprised of FX gains associated with the loans, which resulted from the change in the translation of the loan payable on TRGL’s books
from the loan inception date to the date management changed its intent and decided to settle the loans. The accumulated CTA also included historical FX differences arising from the translation of TRI 2002’s net assets to U.S. dollars for
purposes of the Company’s consolidated financial reporting.

 * * *

As requested by the Commission, Thomson Reuters acknowledges that:

•

Thomson Reuters 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 with respect to the filing; and

•

Thomson Reuters 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.

 4

 Please feel free to contact me at (203) 539-8448 if you have any questions or require any additional
information with respect to the foregoing.

 Sincerely,

 /s/
Linda J. Walker

 Linda J. Walker

 Senior Vice President,
Controller & Chief Accounting Officer

cc:
James Smith, President & Chief Executive Officer

 Stephane Bello, Executive Vice
President & Chief Financial Officer

 Deirdre Stanley, Executive Vice President, General Counsel & Secretary

Marc Gold, Senior Vice President & Associate General Counsel, Corporate & Securities

Thomson Reuters Audit Committee

Joseph R. Tort, PricewaterhouseCoopers LLP

 5

July 10 , 201 5

Stephane Bello
Executive Vice President  Finance and Chief Financial Officer
Thomson Reuters Corporation
3 Times Square
New York , NY 10036

Re: Thomson Reuters  Corporation
 Form 40-F for Fiscal Y ear Ended December  31, 2014
Filed March  13, 201 5
File No. 001-31349

Dear Mr. Bello :

We have reviewed your filing an d have the following comment.  Our comment  asks you
to provide us with information so we may better understand your disclosure s.

Please respond to this letter within ten business days by providing the requested
information.   If you do not believe our comment appl ies to your facts and circumstances, pl ease
tell us why in your response.

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

Exhibit 99.1

Notes to Consolidated Financial Statements

Note 6: Other operating gains, net, pa ge 96

1. You disclose that you recorded in 2014 a $931 million gain related to the release of
accumulated foreign currency translation adjustments from shareholders’ equity that was
triggered by the loss of control of a subsidiary.  So that we may better und erstand your
accounting for this transaction, please tell us the following:

 The name of the subsidiary for which control was lost;
 The location of the subsidiary;
 The nature of the subsidiary’s operations;
 The form of control before the transaction;
 The f orm of control you retained and the subsequent accounting for your investment
going forward;

Stephane Bello
Thomson Reuters  Corporation
July 10 , 2015
Page 2

  Explain how you lost control of the subsidiary through the permanent settlement of an
intercompany loan, an apparent related party transaction, and the facts and c ircumstances
leading to the settlement;
 Cite the accounting literature you relied upon to support your accounting; and
 Provide the calculation on how you computed the gain.

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 co mpany
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 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.

You may contact Patrick Kuhn  at (202) 551 -3308  or Doug Jones at (202) 551 -3309  with any
questions .  You may also call me at (202) 551 -3380.

Sincerely,

 /s/ Lyn Shenk

Lyn Shenk
Branch Chief

November 13 , 2013

Via E -mail
Stephane Bello
Executive Vice President & Chief Financial Officer
Thomson Reuters  Corporation
3 Time s Square
New York, New York, 10036

Re: T homson Reuters Corporation
 Form 40-F for Fiscal Year Ended December 31, 201 2
Filed on March 11, 2013
File No. 001 -31349

Dear Mr. Bello :

We have completed our review of your filing. We remind you that our comments or
changes to disclosure in response to  our comments do not foreclose the Commission from taking
any action with respect to the company or 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 securiti es laws of the United States. 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 rules require.

Sincerely,

 /s/ Lyn Shenk

 Lyn Shenk
Branch Chief

CORRESP
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[THOMSON REUTERS LETTERHEAD]

October 2, 2013

VIA EDGAR/CORRESPONDENCE

Ms. Lyn Shenk

Branch Chief

Division of Corporation Finance

U.S. Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

Re:
Thomson Reuters Corporation

Form 40-F for the Fiscal Year Ended December 31, 2012

Filed March 11, 2013

File No. 001-31349

Dear Ms. Shenk:

We have received your comment letter dated September 3, 2013 related to the above-mentioned filing of Thomson Reuters Corporation.  On September 10, 2013, we discussed the comments with Doug Jones and Aamira Chaudhry of the Staff and they provided us with an extension to respond by October 2, 2013.  Based on our discussions with the Staff, we are providing the following responses.  To assist your review, we have included the text of the comments below in italics.

Form 40-F for Fiscal Year Ended December 31, 2012

 Appendix E

 Critical Accounting Estimates and Judgments, page 72

1.
We note your response to prior comment 2 in regard to the Financial & Risk CGU. You state that the discount and tax rates you use are not specific to you, and that using your actual rates would not be consistent with your methodology that uses the rates of comparable companies operating in similar industries. Please explain to us why you do not use rates that are specific to you based on your actual experience, and why it is more meaningful and appropriate to use rates of comparable companies instead. You also state that you do not compute an actual tax expense for this CGU as your taxes are managed on a legal entity rather than on a CGU basis. In this regard, explain to us why an allocable portion of your consolidated or applicable legal entity tax expense attributable to the contribution of this CGU to either is not considered.

1

Company response:

We do not use discount rates and tax rates that are specific to the company as IFRS does not allow this approach in computing fair value.  Specifically, paragraph 6 of IAS 36, Impairment of Assets, refers to IFRS 13, Fair Value Measurement, for the definition of fair value.  In turn, paragraphs 2 and 3 of IFRS 13 set forth the principles that fair value is a market-based measurement, not an entity-specific measurement, and that fair value must be measured using the assumptions that market participants would use.  As we noted on our call, the effective tax rate for Thomson Reuters is lower than the market participant tax rate we must use in our impairment analysis.  If the impairment analysis had been computed using the Thomson Reuters tax rate, we would have reported more headroom.

To clarify this point in our future disclosures, we propose to add a paragraph substantially similar to the wording below within the discussion of our critical accounting estimates and judgments in management's discussion and analysis:

"Valuation Techniques

IFRS 13 defines fair value as a market-based measurement rather than an entity-specific measurement.  Therefore, the fair value of our CGUs must be measured using the assumptions that market participants would use rather than those related specifically to Thomson Reuters.  In particular, the discount and tax rates for our CGUs reflect market participant assumptions.  To calculate these market participant assumptions, we gathered publicly available data from companies operating in businesses similar to those within each of our CGUs, which includes some of our key competitors."

During the September 10 call, the Staff asked why we use a period of five years for our specific projection period.  Paragraph 35 of IAS 36 establishes a maximum of five years for the specific projection period because reliable projections of future cash flows for periods longer than five years are generally not available under normal circumstances. The Staff requested that we further clarify that our five year projection period is prescribed by IAS 36 and that our growth assumptions refer to cash flow.  To address this point in our future disclosures, we propose to reflect wording substantially similar to the paragraph below within the discussion of our critical accounting estimates and judgments in management's discussion and analysis:

2

"Cash Flow Projections

Cash flow projections were based on our internal budget. We projected cash flows for a period of five years, as prescribed by IAS 36, and applied a perpetual long-term rate thereafter.  In order to project cash flows for the five year period, we considered growth in revenues and costs as well as capital expenditures."

2.
In determining the perpetual growth rate you use, you disclose that assumptions used are based on the internal budget and certain projected variables for a period of five years, and that you consider past experience. You state in the response that by its nature, there is no corresponding actual result for the perpetual growth rate. Since it appears that five years of internal budget information is employed in developing the perpetual growth rate and that past experience is considered, please explain to us why the actual growth rate you experienced in the latest corresponding five year historical period would not be useful information to investors in assessing the reasonableness of your perpetual growth rate assumption. Additionally, please explain to us your consideration of and weight given to the factors you disclosed in regard to this CGU as indicated in our prior comment (i.e., (i) restarting its growth, (ii) a 2013 outlook of low single digit revenue growth, (iii) negative revenue growth in 2012 from 2011, and (iv) the approximately $100 million in expected costs to reduce your workforce predominantly within this CGU) in determining your perpetual growth rate assumption.

Company response:

During our September 10 call, we discussed with the Staff that the basis of our projections is not comparable to historical results. Specifically, we completed several acquisitions and dispositions which distorted trends over time.  Significant costs associated with our Reuters integration program from 2009 – 2011 created additional volatility, as the gradual reduction of integration spending translated into an abnormally high cash flow growth rate over the period which we believe could be misleading for the reader.  Further, any historical metric would have to be computed as a hybrid of actual company-specific pre-tax cash flows and a market rate tax assumption in order to be comparable to the basis of the projections. Given these limitations, the Staff requested that we consider alternative disclosure which would enable a reader to assess the reasonableness of our cash flow projections.

While specific facts and circumstances will dictate the actual, future disclosure, below we have included an example of how we might have reflected our 2012 annual report disclosure related to our Financial & Risk CGU within the discussion of our critical accounting estimates and judgment to achieve this objective:

"The DCF valuation for the Financial & Risk CGU assumes that free cash flow will grow at a compounded annual rate of 5.1% from 2012 to 2017 and by 3% thereafter. We believe that these projections appropriately consider the current economic environment and the markets served by Financial & Risk. Over the next five years, our cash flow projections assume a gradual improvement in Financial & Risk's operating income margin. This improvement will initially be dependent primarily on various initiatives we are undertaking to reduce costs, primarily by reducing our workforce, as we decommission legacy platforms and infrastructures as customers upgrade to new products and services, such as Eikon and Elektron. Our projections for perpetual cash flow growth assume that the Financial & Risk business will return to positive revenue growth gradually over time and that it will increase prices in line with inflation. In 2012, the year following our 2011 impairment charge, we note that our actual 2012 cash flow performance achieved the 2012 projection included within our 2011 impairment testing analysis, after adjusting for market participant assumptions such as the tax rate.”

3

Relative to our consideration of and weight given to the factors highlighted by the Staff in its comment, we note the following:

·
As discussed on our call, our 2013 outlook of low single digit revenue growth is for Thomson Reuters on a consolidated basis and not for the Financial & Risk CGU on a standalone basis.

·
Relative to the other factors highlighted in the comment, please refer to our proposed disclosure above which emphasizes the assumptions underlying our growth projections.

3.
Please explain to us in more detail why you believe that a comparison of the actual free cash flow rate in a current period with the long-term compound annual growth rate assumption would not be helpful to an investor. From your response it appears the assumed free cash flow rate is for a five year period and is based on internal information. In this regard, please explain to us why the actual free cash flow rate you experienced in the latest corresponding five year historical period would not be useful information to investors in assessing the reasonableness of your free cash flow rate assumption.

Company response:

Please refer to our proposed disclosure above within our response to comment 2.

Please feel free to contact me at (203) 539-8448 if you have any questions or require any additional information with respect to the foregoing.

Sincerely,

/s/ Linda J. Walker

Linda J. Walker

Senior Vice President & Chief Accounting Officer

cc:
Jim Smith, President & Chief Executive Officer

Stephane Bello, Executive Vice President & Chief Financial Officer

Deirdre Stanley, Executive Vice President & General Counsel

Marc Gold, Senior Vice President & Associate General Counsel, Corporate & Securities

Thomson Reuters Audit Committee

Joseph Tort, PricewaterhouseCoopers LLP

John Pope, PricewaterhouseCoopers LLP

Andrew J. Beck, Torys LLP

4

CORRESP
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[THOMSON REUTERS LETTERHEAD]

September 12, 2013

VIA EDGAR/CORRESPONDENCE

Ms. Lyn Shenk

Branch Chief

Division of Corporation Finance

U.S. Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

Re:

Thomson Reuters Corporation

Form 40-F for the Fiscal Year Ended December 31, 2012

Filed March 11, 2013

File No. 001-31349

Dear Ms. Shenk:

We have received your comment letter dated September 3, 2013 related to the above-mentioned filing of Thomson Reuters Corporation. Pursuant to a telephone discussion on September 10, 2013 with Aamira Chaudhry and Doug Jones of the Staff, I am confirming that the Staff has granted our request for an extension of the deadline to respond to the comment letter to October 2, 2013. We intend to respond to the comment letter on or before October 2, 2013.

Please feel free to contact me at (203) 539-8448 if you have any questions or require any additional information with respect to the foregoing.

Sincerely,

/s/ Linda J. Walker

Linda J. Walker

Senior Vice President & Chief Accounting Officer

cc:

Marc Gold, Senior Vice President & Associate General Counsel, Corporate & Securities

Andrew J. Beck, Torys LLP

September 3 , 2013

Via E -mail
Stephane Bello
Executive Vice President & Chief Financial Officer
Thomson Reuters  Corporation
3 Time s Square
New York, New York, 10036

Re: T homson Reuters Corporation
 Form 40-F for Fiscal Year Ended December 31, 201 2
Filed on March 11, 2013
File No. 001 -31349

Dear Mr. Bello :

We have reviewed your response letter dated July 23, 2013 and have the following
comments. In our comments, we ask you to provide us with information so we may better
understand your disclosure.

Please r espond to this letter within 10  business days by confirming that you will revise
your document in future filings  and providing any  reque sted information.   If you do no t believe
our comments apply to your facts and circumstances, please  tell us why in your response.

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

Form 40 -F for Fiscal Year Ended Dece mber 31, 2012

Appendix E

Critical Accounting Estimates and Judgments, page 72

1. We note your response to prior comment 2 in regard to the Financial &  Risk CGU.  You
state that the discount and tax rates you use are not specific to you, and that using your
actual rates would not be consistent with your methodology that uses the rates of
comparable companies operating in similar industries.  Please expla in to us why you do
not use rates that are specific to you based on your actual experience, and why it is more
meaningful and appropriate to use rates of comparable companies instead.  You also state
that you do not compute an actual tax expense for this C GU as your taxes are managed
on a legal entity rather than on a CGU basis.  In this regard, explain to us why an
allocable portion of your consolidated or applicable legal entity tax expense attributable

Stephane Bello
Thomson Reuters  Corporation
September 3 , 2013
Page 2

 to the contribution of this CGU to either is not con sidered.

2. In determining the perpetual growth rate you use, you disclose that assumptions used are
based on the internal budget and certain projected variables for a period of five years, and
that you consider past experience.  You state in the response th at by its nature, there is no
corresponding actual result for the perpetual growth rate.  Since it appears that five years
of internal budget information is employed in developing the perpetual growth rate and
that past experience is considered, please exp lain to us why the actual growth rate you
experienced in the latest corresponding five year historical period would not be useful
information to investors in assessing the reasonableness of your perpetual growth rate
assumption.    Additionally, please exp lain to us your consideration of and weight given
to the factors you disclosed in regard to this CGU as indicated in our prior comment (i.e.,
(i) restarting its growth, (ii) a 2013 outlook of low single digit revenue growth, (iii)
negative revenue growth i n 2012 from 2011, and (iv) the approximately $100 million in
expected costs to reduce your workforce predominantly within this CGU) in determining
your perpetual growth rate assumption.

3. Please explain to us in more detail why you believe that a comparison  of the actual free
cash flow rate in a current period with the long -term compound annual growth rate
assumption would not be helpful to an investor.  From your response it appears the
assumed free cash flow rate is for a five year period and is based on i nternal information.
In this regard, please explain to us why the actual free cash flow rate you experienced in
the latest corresponding five year historical period would not be useful information to
investors in assessing the reasonableness of your free cash flow rate assumption.

You may contact Aamira Chaudhry at 202 -551-3389 or Doug Jones at 202 -551-3309 if
you have questions regarding comments on the financial statements and related matters.  Please
contact me at 202 -551-3380 with any other question s.

Sincerely,

 /s/ Lyn Shenk

 Lyn Shenk
Branch Chief

CORRESP
1
filename1.htm

[THOMSON REUTERS LETTERHEAD]

July 23, 2013

VIA EDGAR/CORRESPONDENCE

Ms. Lyn Shenk

Branch Chief

Division of Corporation Finance

U.S. Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

Re:
Thomson Reuters Corporation

Form 40-F for the Fiscal Year Ended December 31, 2012

Filed March 11, 2013

File No. 001-31349

Dear Ms. Shenk:

We have received your comment letter dated July 10, 2013 related to the above-mentioned filing of Thomson Reuters Corporation.  With respect to the items in that letter, we are providing the following responses.  To assist your review, we have included the text of the comments below in italics.

Form 40-F for Fiscal Year Ended December 31, 2012

Exhibit 99.1

Management's  Discussion  and  Analysis

Financial Position, page 49

1.
You state that the carrying amounts of your total current liabilities exceeded the carrying amounts of your total current assets principally because current liabilities include deferred revenue.  It appears the working capital deficiency is due to the use of the cash received from the deferred revenues for other investing and financing purposes.  Please revise your disclosure accordingly or advise.

1

Company response:

In future filings, beginning with our second quarter 2013 Management's Discussion and Analysis, we will revise and supplement our existing disclosure to clarify that our working capital deficiency is typical of our business model, but is not indicative of a liquidity issue. Specifically, we plan to further emphasize and clarify that:

·
Thomson Reuters derives a majority of its revenues from the sale of information and services delivered electronically on a subscription basis, for which many customers pay in advance.

·
For accounting purposes, these advance payments must be deferred and recognized as revenues over the term of the subscription. However, the cash received from these advance payments is used to currently fund the operating, investing and financing activities of our business. As such, we typically reflect a working capital deficiency in our balance sheet.

·
In the ordinary course of our business, deferred revenue does not represent a cash liability, but rather an obligation to perform services or deliver products. Accordingly, our working capital deficiency does not indicate a liquidity issue, but rather an outcome of the required accounting for our business model.

A significant balance of deferred revenue is typical of our business model.  However, despite the working capital deficiency that results from this dynamic, our business model has been highly cash generative and our liquidity position has been strong.

 In 2012, we generated $2.7 billion of net cash from our operating activities after funding our operating expenses, which are primarily comprised of staff costs, as well as interest, taxes and other expenses.  We used cash provided by our operating cash flows and proceeds from disposals of businesses to fund our investing and financing activities, including capital expenditures, acquisitions of businesses and dividends to shareholders.  After our operating, investing and financing activities, we recorded a net increase in cash and cash equivalents of $879 million and total cash and cash equivalents of $1.3 billion at December 31, 2012. Our cash balance fluctuates, often reflecting our investing activities.  However, we note by comparison that we reported cash and cash equivalents of $422 million at December 31, 2011 and $423 million at March 31, 2013, demonstrating our strong liquidity position.

Appendix E

Critical Accounting Estimates and Judgments, page 72

2.
You disclose on the bottom of page 73 that the fair value of the Financial & Risk CGU exceeded its carrying value by 6%.  In regard to this CGU, you disclose elsewhere in your filing (i) about restarting its growth, (ii) a 2013 outlook of net negative sales, (iii) that revenues grew 1% in 2012 from 2011, and (iv) that the approximately $100 million in expected costs to reduce your workforce will be predominantly within Financial & Risk. Given the preceding, please consider expanding your disclosure to address the actual discount, tax, perpetual growth and annual free cash flow rates that you have recently experienced applicable to the Financial & Risk CGU to give investors a relative perspective in regard to achieving the assumed rates and the potential for reduction in the fair value.

2

Company response:

We believe our continuous disclosures provide investors with meaningful information regarding our Financial & Risk CGU's actual performance, outlook and material trends.   We plan to continue providing such disclosures in our future filings.  After considering the Staff's comment, we believe that expanding our existing disclosures to address actual discount, tax, perpetual growth, and free cash flow rates that we have recently experienced would not be helpful to investors as such disclosures would not be consistent with the methodology used to determine the fair value of the Financial & Risk CGU in our annual assessment of goodwill.  Specifically:

·
Discount rate – As we disclosed on page 73 of our 2012 Form 40-F, the discount rate used to calculate the present value of our projected cash flows represented a weighted average cost of capital (WACC) for comparable companies operating in similar industries as the applicable CGU, based on publicly available information.  As the WACC is not specific to Thomson Reuters or to Financial & Risk, we believe that it would not be helpful to calculate and disclose an actual WACC that is derived from the Company's actual business results, as it would not be consistent with the methodology used to determine the fair value of the Financial & Risk CGU in our annual assessment of goodwill.

·
Tax rate – As disclosed on page 73 of our 2012 Form 40-F, the tax rate applied to the projections was based on effective tax rates of comparable companies operating in similar industries as the applicable CGU, based on publicly available information. Similar to the WACC, the tax rate assumption is not specific to Thomson Reuters or to Financial & Risk. Therefore, we believe it would not be helpful to calculate and disclose an actual tax rate derived from Financial & Risk's business results, as it would not be consistent with the methodology used to determine the fair value of the Financial & Risk CGU in our annual assessment of goodwill.

·
Perpetual growth rate – The perpetual growth rate assumption reflects expectations over the long-term and specifically beyond the five year discrete forecasting period.  By its nature, there is no corresponding actual result. The assumption considers past experience, long-term economic trends such as GDP growth and inflation as well as long-term industry and market trends. Given the long-term nature of this assumption, we believe it is most useful to reassess it annually in conjunction with our annual assessment of goodwill, or sooner if events and circumstances suggest that an impairment test is required.

3

·
Annual free cash flow rates – As disclosed on page 74 of our 2012 Form 40-F, the discounted cash flow valuation for the Financial & Risk CGU assumes free cash flow will grow at a compounded annual rate of 5.1% from 2012 to 2017. The pre-tax cash flows associated with this assumption were derived from our internal forecasting and planning process.  We believe that the comparison of actual free cash flow rates for the Financial & Risk CGU in a current period with the long-term compound annual growth rate assumption would not be helpful to an investor. Further, as described above, the tax assumption incorporated into the free cash flow assumptions was derived from comparable company analysis. We do not compute an actual tax expense for Financial & Risk, as we manage our taxes on a legal entity rather than on a CGU basis. In addition, a tax rate based specifically on Thomson Reuters' actual tax position would not be consistent with the methodology used to determine the fair value of the Financial & Risk CGU in our annual assessment of goodwill.

As the Staff is aware, we are required under IFRS to test our goodwill and indefinite lived intangible assets for impairment on an annual basis, or more often if events or changes in circumstances indicate that impairment may have occurred.  We will update our assumptions based on comparable company data, as well as our long term growth assumptions, in conjunction with our impairment tests.

Form 6-K Filed on May 2, 2013

Exhibit 99.1- Management's  Discussion  and  Analysis

Consolidated Results- Tax (expense) benefit, page 7

3.
In the three months ended March 31, 2013, you recorded a $235 million tax charge in conjunction with the further consolidation of the ownership and management of your technology and content assets.  Please explain to us in detail the associated facts and circumstances and why taxes were impacted to this extent.

Company response:

In the first quarter of 2013, one of our wholly owned U.S. subsidiaries sold certain technology and content assets to one of our wholly owned non-U.S. subsidiaries for a $700 million interest-bearing note that is payable over seven years.  The $700 million sale price represents the fair market value of the assets. The book value of the assets sold was $65 million, which produced a gain of $635 million for the U.S. subsidiary.  The gain is taxable in the U.S. at a rate of 37%, or $235 million. In accordance with IAS 12, we recorded a tax charge of $235 million in the three month period ended March 31, 2013 and an offsetting deferred tax liability, as the U.S. tax will be payable over the term of the note as principal is repaid.  The transaction did not generate an offsetting deferred tax asset outside of the U.S. because the acquired tax basis is not deductible by the non-U.S. subsidiary.

4

*   *   *

As requested by the Commission, Thomson Reuters acknowledges that:

·
Thomson Reuters is responsible for the adequacy and accuracy of the disclosures in its filing;

·
Staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing; and

·
Thomson Reuters 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.

Please feel free to contact me at (203) 539-8448 if you have any questions or require any additional information with respect to the foregoing.

Sincerely,

/s/ Linda J. Walker

Linda J. Walker

Senior Vice President & Chief Accounting Officer

cc:
Jim Smith, President & Chief Executive Officer

Stephane Bello, Executive Vice President & Chief Financial Officer

Deirdre Stanley, Executive Vice President & General Counsel

Marc Gold, Senior Vice President & Associate General Counsel, Corporate & Securities

Thomson Reuters Audit Committee

Joseph Tort, PricewaterhouseCoopers LLP

John Pope, PricewaterhouseCoopers LLP

Andrew J. Beck, Torys LLP

5

July 10, 2013

Via E -mail
Stephane Bello
Executive Vice President & Chief Financial Officer
Thomson Reuters  Corporation
3 Time s Square
New York, New York, 10036

 Corrected
Re: T homson Reuters Corporation
 Form 40-F for Fiscal Year Ended December 31, 201 2
Filed on March 11, 2013
File No. 001 -31349

Dear Mr. Bello :

We have reviewed your filing and have the following comments.  In some of our
comments, we may ask you to provide us  with information so we may better understand your
disclosure.

Please r espond to this letter within 10  business days by confirming that you will revise
your document in future filings  and providing any  reque sted information.   If you do not believe
our com ments apply to your facts and circumstances, please  tell us why in your response.

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

Form 40 -F for Fiscal Year Ended December 31, 2012

Exhibit 99.1

Management’s Discussion and Analysis

Financial Position, page 49

1. You state that the carrying amounts of your total current liabilities exceeded the carrying
amounts of your total current assets principally because current liabilities include
deferred revenue.  It appears the working capital deficiency is due to the use of the cash
received from the deferred revenues for other investing and financing purposes.  Please
revise your disclosure accordingly or advise.

Stephane Bello
Thomson Reuters  Corporation
July 10, 2013
Page 2

Appendix E

Critical Account ing Estimates and Judgments, page 72

2. You disclose on the bottom of page 73 that the fair value of the Financial & Risk CGU
exceeded its carrying value by 6%.  In regard to this CGU, you disclose elsewhere in
your filing (i) about restarting its growth, (ii) a 2013 outlook of net negative sales, (iii)
that revenues grew 1% in 2012 from 2011, and (iv) that the approximately $100 million
in expected costs to reduce your workforce will be predominantly within Financial &
Risk.  Given the preceding, please co nsider expanding your disclosure to address the
actual discount, tax, perpetual growth and annual free cash flow rates that you have
recently experienced applicable to the Financial & Risk CGU to give investors a relative
perspective in regard to achieving  the assumed rates and the potential for reduction in the
fair value.

Form 6 -K Filed on May 2, 2013

Exhibit 99.1 - Management’s Discussion and Analysis

Consolidated Results - Tax (expense) benefit, page  7

3. In the three months ended March 31, 2013, you recorded a $235 million tax charge in
conjunction with the further consolidation of the ownership and management of your
technology and content assets.  Please explain to us in detail the associated facts a nd
circumstances and why taxes were impacted to this extent.

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 a nd all applicable Exchange Act rules require.   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 responding t o 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 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.

Stephane Bello
Thomson Reuters  Corporation
July 10, 2013
Page 3

You may contact Aamira Chaudhry at 202 -551-3389 or Doug Jones at 202 -551-3309 if
you have questions regarding comments on the financial statements and related matters.  Please
contact me at 202 -551-3380 with any other questions.

Sincerely,

 /s/ Lyn Shenk

 Lyn Shenk
Branch Chief

CORRESP
1
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    tpcorresp_thomson.htm

July 31, 2012

VIA EDGAR AND CERTIFIED MAIL

Ms. Peggy Kim

Special Counsel

Division of Corporation Finance – Office of Mergers & Acquisitions

U.S. Securities & Exchange Commission

100 F. Street, N.E.

Washington D.C. 20549

Re:

FX Alliance Inc.

Schedule TO filed on July 18, 2012 (as amended)

Filed by CB Transaction Corp., Thomcorp Holdings Inc. and

Thomson Reuters Corporation

File No. 5-86898

Dear Ms. Kim:

This letter sets forth the response of CB Transaction Corp., Thomcorp Holdings Inc. and Thomson Reuters Corporation (collectively, the “Bidders”) to the comment letter, dated July 26, 2012 (the “Comment Letter”), of the staff of the Division of Corporation Finance – Office of Mergers & Acquisitions (the “Staff”) relating to the Bidder’s Tender Offer Statement on Schedule TO filed with the U.S. Securities and Exchange Commission (the “Commission”) on July 18, 2012 (as amended and supplemented from time to time, the “Schedule TO”).

In order to facilitate your review, we have repeated each comment from the Comment Letter in its entirety in italics in the original numbered sequence.  Page references in the responses below are to the Schedule TO.  Capitalized terms used but not otherwise defined herein shall have the meanings ascribed to such terms in the Schedule TO.

FX Projections, page 28

1.

We note that certain projections of the future operating performance of FX have not been prepared in accordance with GAAP. As a result, please revise or advise us as to what consideration you have given to whether additional disclosure is required pursuant to Rule 100(a) of Regulation G. We may have additional comments after we review your response. Please refer to Question 101.01 in the Non-GAAP Financial Measures section of the Division’s Compliance and Disclosure Interpretations.

Response:

In Amendment No. 2 to the Schedule TO filed by the Bidders with the SEC on July 31, 2012, we revised the disclosure to reconcile FX’s projections of “Operating Expenses,” “Adjusted EBITDA,” “Adjusted EBIT” and “Adjusted Net Income” to financial measurements prepared in accordance with GAAP.

Source and Amount of Funds, page 3

2.

We note that Thomson Reuters will have sufficient funds to purchase all shares tendered. Please revise to state the specific source of funds and if any part of the funds is expected to be borrowed, please describe the loan agreement and file the agreement as an exhibit. Refer to Item 1007(a) and (d) and Item 1016(b) of Regulation M-A.

Response:

In Amendment No. 2 to the Schedule TO filed by the Bidders with the SEC on July 31, 2012, we revised the disclosure to indicate that we expect to fund the purchase of shares tendered with the funds provided by Thomson Reuters and its subsidiaries either through one or more capital contributions or as an intercompany loan (the terms of any such intercompany loan have not yet been determined).  Thomson Reuters and its subsidiaries will obtain such funds from cash on hand and/or cash generated from general corporate operating activities.

Lock-Up Waivers, page 57

3.

We note that according to section 6.1 of the Tender and Support Agreement, stockholders will not be obligated to pay any costs, fees or expenses in connection with obtaining the Lock-Up Waiver. Please disclose whether any fees or payments were paid and the amount of any fees paid to Merrill Lynch and GS in connection with obtaining the Lock-Up Waiver and whether the bidders paid any part of the expense. If the bidder paid any fees in connection with the Lock-Up Waiver, please advise us as to how the bidders are complying with the best price provision in Rule 14d-10(a)(2).

Response:

In Amendment No. 1 to the Schedule TO filed by the Bidders with the SEC on July 26, 2012, we revised the disclosure to indicate that no fees or payments were paid to Merrill Lynch and GS in connection with obtaining the Lock-Up Waivers.  In addition, in Amendment No. 2 to the Schedule TO filed by the Bidders with the SEC on July 31, 2012, we filed the Lock-Up Waivers as Exhibits (d)(6), (d)(7), and (d)(8).

*     *     *

As requested by the Staff in the Comment Letter, the Bidders have authorized us to confirm the following on its behalf:

●

Each Bidder is responsible for the adequacy and accuracy of the disclosure in the filing;

●

Staff comments or changes to disclosures in response to Staff comments do not foreclose the Commission from taking any action with respect to the filing; and

●

Each Bidder 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.

Should you or any other member of the Staff have any questions regarding our responses, or need additional information, please do not hesitate to call David Shine or me at (212) 859-8000.

Sincerely,

/s/ Tiffany Pollard

Tiffany Pollard

cc:      Priscilla C. Hughes, Senior Vice President, General Counsel, Americas and Chief Counsel, M&A, of Financial & Risk, Thomson Reuters Corporation

May 30, 2012

Via E -mail
Stephane Bello
Chief Financial Officer
Thomson Reuters Corporation
3 Times Square
New York, NY  10036

Re: Thomson Reuters Corporation
 Form 40-F for Fiscal Year Ended December 31 , 2011
Filed March  19, 201 2
File No. 001-31349

Dear Mr. Bellow :

We have reviewed your filing  and have the following comment.  In our comment, we
may ask you to provide us with information so we may better understand your disclosure.

Please r espond to this letter within 10  business days by confirming that you will revise
your document in future filings  and providing any requested information .  If you do not believe
our comment  apply  to your facts and circumstances, please tell us why in your response.

After reviewing any amendment to your filing and the information you provide in
response to these comment, we may have additional comments.

Form 40-F for Fiscal Year  Ended December  31, 2012

Other Businesses, page 11

1. We note disclosure in exhibits 99.1 and .2 of the Form 6 -K filed on May 3, 2012
reporting your interim results for the period ended March 31, 2012 that you entered into a
definitive agreement to sell the Health care business for $1.25 billion and that you expect
a significant gain on the transaction.  In this filing you include the Healthcare business in
“other businesses,” which is an aggregation of businesses reported within continuing
operations that have been  or are expected to be exited through sale or closure that d o not
qualify for discontinued operations classification .  We also note that the Healthcare
business appears to have been a component of the “Healthcare & Science” reportable
segment previously pr esented.  Please explain to us your basis for not classifying the
healthcare business as a discontinued operation pursuant to paragraphs 31 and 32(a) of
International Financial Reporting Standard 5 when the business appears to be a
component that represent s a separate major line of business.

Stephane Bello
Thomson  Reuters Corporation
May 30, 2012
Page 2

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 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 responding to our comments, p lease 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 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.

You may c ontact T heresa Messinese at 202 -551-3307 or Doug Jones at 202 - 551-3309 if
you have questions regarding the comment s and related  matters .  Please contact me at 202 -551-
3380 with any other questions.

Sincerely,

 /s/ Lyn Shenk

 Lyn Shenk
Branch Chief

CORRESP
1
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[THOMSON REUTERS LETTERHEAD]

June 6, 2012

VIA EDGAR/CORRESPONDENCE

Ms. Lyn Shenk

Branch Chief

Division of Corporation Finance

U.S. Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

Re:

Thomson Reuters Corporation

Form 40-F for Fiscal Year Ended December 31, 2011

Filed March 19, 2012

File No. 001-31349

Dear Ms. Shenk:

We have received your comment letter dated May 30, 2012 related to the above-mentioned filing of Thomson Reuters Corporation.  With respect to the item in that letter, we are providing the following response.  To assist your review, we have included the text of the comment below in italics.

Form 40-F for Fiscal Year Ended December 31, 2011

Other Businesses, page 11

1.

We note disclosure in exhibits 99.1 and .2 of the Form 6-K filed on May 3, 2012 reporting your interim results for the period ended March 31, 2012 that you entered into a definitive agreement to sell the Healthcare business for $1.25 billion and that you expect a significant gain on the transaction.  In this filing you include the Healthcare business in “other businesses,” which is an aggregation of businesses reported within continuing operations that have been or are expected to be exited through sale or closure that do not qualify for discontinued operations classification.  We also note that the Healthcare business appears to have been a component of the “Healthcare & Science” reportable segment previously presented.  Please explain to us your basis for not classifying the Healthcare business as a discontinued operation pursuant to paragraphs 31 and 32(a) of International Financial Reporting Standard 5 when the business appears to be a component that represents a separate major line of business.

1

Company response:

While the Healthcare business constituted a component of Thomson Reuters, it did not meet the applicable criteria in IFRS 5 to be considered a discontinued operation.

To aid the Staff’s understanding, the first part of our response summarizes the chronology of the divestiture process, including relevant disclosures and information regarding our classification of the business as held for sale at applicable points in time.  The second part of our response addresses our basis for concluding that the business did not qualify as a discontinued operation.

Chronology of the Divestiture Process:

●

On June 6, 2011, we issued a news release announcing our intention to divest our Healthcare business. A copy of the news release was included as Exhibit 99.1 to our Form 6-K furnished on June 7, 2011. In the news release, we stated that we expected the divestiture to close before the end of the year.

Ø

In June 2011, we classified Healthcare as held for sale. At that time, we had met the criteria in paragraphs 7 and 8 of IFRS 5, including actively marketing the business and concluding that a sale was highly probable within a year.

●

In December 2011, we announced that we had suspended the divestiture process for Healthcare due to challenging global economic conditions and that we expected to resume the process when market conditions allowed us to complete the divestiture at attractive terms. We referred to our initial announcement and the suspension of the divestiture process in our annual report on Form 40-F for the year ended December 31, 2011 which was filed on March 19, 2012. That disclosure was reflected in note 13 to our annual audited financial statements and in the “Acquisitions and Dispositions” section of our annual management’s discussion and analysis.

Ø

As a result of the announcement, we concluded that Healthcare no longer qualified as held for sale at December 31, 2011.  Specifically, we concluded that we did not meet the held for sale criteria per paragraph 8 of IFRS 5 at December 31, 2011 because at that time:  (1) we were not actively conducting a program to market the business and (2) we were uncertain about when we would resume the divestiture process given market conditions, and therefore we could not say that a sale was highly probable within a year.

●

In note 11 to our interim financial statements for the quarter ended March 31, 2012 (Exhibit 99.2 to our Form 6-K furnished on May 3, 2012), we stated that in the first quarter of 2012, we resumed the divestiture process for Healthcare.

Ø

Given that we were progressing discussions with prospective purchasers, we now believed that closing the divestiture within a year was highly probable.  Therefore, we re-classified the business as held for sale at March 31, 2012.

●

On April 23, 2012, we issued a news release announcing our signing of a definitive agreement to sell the Healthcare business. A copy of the news release was included as Exhibit 99.1 to our Form 6-K dated April 23, 2012. In the news release, we stated that we expected the divestiture to close in the next few months.

2

Basis for not classifying Healthcare as a Discontinued Operation:

Given that Healthcare did not qualify for held for sale classification at December 31, 2011, it did not meet the criteria in paragraph 32 of IFRS 5 to be considered as a discontinued operation as of year-end. Following is the basis for our conclusion that Healthcare did not qualify as a discontinued operation during the periods when it met the held for sale criteria.

IFRS 5 paragraph 32 (cited by the Staff in its comment) provides that a discontinued operation is “a component of an entity that either has been disposed of, or is classified as held for sale, and

(a)

represents a separate major line of business or geographical area of operations,

(b)

is part of a single co-ordinated plan to dispose of a separate major line of business or geographical area of operations, or

(c)

is a subsidiary acquired exclusively with a view to re-sale.”

Management concluded that Healthcare constituted a component, which is defined in paragraph 31 of IFRS 5 as one which “comprises operations and cash flows that can be clearly distinguished, operationally and for financial reporting purposes, from the rest of the entity”.  We note to the Staff that we had consistently treated the businesses comprising Healthcare as cash generating units for purposes of our annual impairment testing.

Management concluded as follows that none of the three additional criteria in paragraph 32 of IFRS 5 for discontinued operation treatment applied to the sale of the Healthcare business:

(a)

Separate major line of business - Management concluded that Healthcare did not represent a significant enough portion of the Thomson Reuters business to qualify as a separate major line of business.  IFRS 5 does not define criteria for a separate major line of business. We considered the quantitative financial information for the Healthcare business set forth below in forming our conclusion:

Percent of Thomson Reuters Corporation

(consolidated)

Healthcare Financial Statement Measure

2011

2010

Revenues

3.5%

3.5%

Segment operating profit

3.5%

3.7%

Assets (as of year-end)

2.0%

1.9%

3

Although a component of an operating segment may qualify as a major line of business, management concluded that Healthcare did not qualify as its relative contribution to the Thomson Reuters business was less than 5% of the key financial statement measures highlighted above.  Reflecting this lack of significance, management noted that Healthcare had not been reported separately to the Chief Operating Decision Maker for Thomson Reuters, but rather had been treated as a component of the reportable segment, Healthcare & Science. In evaluating fair value measurement, management also considered that Healthcare’s anticipated sale price would represent about 5% of our market capitalization at June 30, 2011, the initial date of our analysis.  For reference, the actual sale price of approximately $1.25 billion represented about 5.2% of Thomson Reuters’ market capitalization at March 31, 2012.

(b)

Single co-ordinated plan –This provision was not relevant to the sale of the Healthcare business, which was not part of a larger plan to dispose of a major line of business or to exit a geographical area.

(c)

Subsidiary acquired exclusively with a view to re-sale –This provision also was not relevant to the sale of the Healthcare business as most of the businesses which comprised Healthcare have been operated by Thomson Reuters for many years. Neither the Healthcare business nor individual units within it had been acquired exclusively with a view to re-sale.

*   *   *

As requested by the Commission, Thomson Reuters acknowledges that:

●

Thomson Reuters is responsible for the adequacy and accuracy of the disclosures in the filing;

●

Staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing; and

●

Thomson Reuters 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.

4

Please feel free to contact me at (203) 539-8448 if you have any questions or require any additional information with respect to the foregoing.

Sincerely,

/s/ Linda J. Walker

Linda J. Walker

Senior Vice President, Controller & Chief Accounting Officer

cc:

Jim Smith, President & Chief Executive Officer

Stephane Bello, Executive Vice President & Chief Financial Officer

Deirdre Stanley, Executive Vice President & General Counsel

Marc Gold, Senior Vice President & Associate General Counsel, Corporate & Securities

Thomson Reuters Audit Committee

John Pope, PricewaterhouseCoopers LLP

Andrew J. Beck, Torys LLP

5

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

       DIVISION OF
CORPORATION FINANCE

        September 2, 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 completed our reviews of your  Form 40-F and Form 20-F and have no
further comments at this time.
Sincerely,

Lyn Shenk Branch Chief

CORRESP
1
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    corresp.htm

[THOMSON REUTERS LETTERHEAD]

July 31, 2009

VIA EDGAR/CORRESPONDENCE

Ms. Lyn Shenk

Branch Chief

Division of Corporation Finance

U.S. Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

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 and File No. 333-08354

Dear Ms. Shenk:

We have received your comment letter dated July 15, 2009 related to the above-mentioned filings of Thomson Reuters Corporation and Thomson Reuters PLC.  With respect to each of the items in that letter, we are providing the following responses.  To assist your review, we have included the text of the comments below in
italics.

Form 40-F and Form 20-F for the fiscal 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 sales (COS) and selling, marketing, general and administrative expenses (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 amounts of major components of expenses within these categories, such as labor, technology costs, information
and licensing costs, or other sub-categories, as appropriate.

Company response: In future filings, beginning with our second-quarter 2009 report, we will explicitly discuss and analyze our operating expenses in our Management’s Discussion and Analysis.

2.

Please ensure that you quantify material factors 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 underlying reason for the
factors.  For example, if known, explain why transaction revenues were higher.

Company response: In our Management’s Discussion and Analysis, we traditionally quantify the revenue variances arising from (a) existing businesses, (b) acquisitions and (c) the impact of foreign exchange, and we explain underlying reasons for these variances when material.  A
specific quantification was not included in our Canadian GAAP discussion for the Markets division in our joint Form 40-F/20-F because of the overwhelming impact of the Reuters Group PLC acquisition on this segment.  However, on page 26 of our Management’s Discussion and Analysis, we did quantify these variances for this segment’s pro forma revenues, which presented the results for the Markets division as though Reuters Group PLC (“Reuters”) had been acquired as of January 1,
2007.  We believed that, due to the significance of the Reuters acquisition on our Markets division, it was more meaningful to focus our analysis on the segment’s pro forma revenues.  In future filings, we will ensure that material factors to which variances are attributed are quantified in our GAAP discussion.

3.

We note from your footnotes that you undertake a significant number of hedging transactions for currencies and interest rates, among other items.  However, it is not clear what aggregate effect these transactions have on your results of operations from period to period.  To the extent available, please tell us what aggregate impact hedging and derivative transactions have had
on your results of operations for each of the years in the three year period ending December 31, 2008.

Company Response: As detailed in Note 16 of our financial statements, over the prior three years, we have primarily entered into fixed-to-fixed and fixed-to-floating cross-currency interest rate swaps to hedge the foreign currency and interest rate exposures on our foreign currency-denominated
debt.  The following table indicates the impact these instruments had on our pre-tax earnings for each of the years in the three year period ending December 31, 2008:

Increase/(decrease) to pre-tax earnings due to:

Year ended December 31,

2008

2007

2006

(in US$ millions)

Foreign exchange gains/losses

(565
)

292

2

Interest expense

22

23

15

Subtotal: Effective portions of derivative instruments

(543
)

315

17

Ineffective portions of derivative instruments

(3
)

-

-

Total

(546
)

315

17

2

In the table above, the effective portions mitigated equal and opposite impacts from exposures on our foreign currency-denominated debt.  The impacts from the ineffective portions of our derivative instruments were minor.

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 intangible assets such as trade names and customer relationships.  Based upon the discussion provided on page 10 it appears that intangible assets other than those identified exist in the business.  Please tell us what consideration was given to allocating the purchase
price to these intangibles.

Company Response: In valuing the acquired assets of Reuters, we considered all assets identified in Appendix A of both the Canadian Institute of Chartered Accountants Handbook Section 1581, Business Combinations, and Statement
of Financial Accounting Standard No. 141, Business Combinations, which include those listed on page 10 of our joint Form 40-F/20-F.  All identifiable intangible assets that were material were valued.  Aside from the trade names and customer relationships, other intangible assets including databases and images were valued at $15 million in aggregate.  The intangible assets discussed on page 10 of our joint Form 40-F/20-F represent
the significant intangible assets for Thomson Reuters as a whole and not only those acquired with Reuters.

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 although these operations were previously presented as four reportable segments prior to the acquisition.  Please tell us what consideration was given to continuing to report these as separate reportable segments.

Company Response:  Prior to our acquisition of Reuters, our chief operating decision maker regularly reviewed and assessed performance, and made decisions about resource allocation, based upon our financial business unit being one operating segment and one reportable segment.  In
conjunction with the acquisition of Reuters, we re-evaluated our operating and reportable segments in accordance with Canadian Institute of Chartered Accountants Handbook Section 1701, Segment Disclosures (“CICA 1701”).  Our chief operating decision maker continues to regularly review and assess performance, and make decisions about resource allocation, based upon our financial business unit being one operating and reportable segment.  Therefore,
in accordance with paragraph 10.b. of CICA 1701, we presented our Markets division as a single reportable segment.

3

*   *   *

As requested by the Commission, Thomson Reuters acknowledges that:

·

Thomson Reuters is responsible for the adequacy and accuracy of the disclosures in its 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 filings; and

·

Thomson Reuters 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.

Sincerely,

/s/ Robert D. Daleo

Robert D. Daleo

Executive Vice President and Chief Financial Officer

cc:

Vance K. Opperman, Chairman of the Audit Committee

Thomas H. Glocer, Chief Executive Officer

Deirdre Stanley, Executive Vice President and General Counsel

Linda J. Walker, Senior Vice President, Controller and Chief Accounting Officer

4

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