[Global Crossing Limited Logo]
December 30, 2009
Mr. Larry Spirgel
Assistant Director
Division of Corporation Finance
United States Securities and Exchange Commission
100 F Street, N.E.
Washington, DC 20549
RE: Global Crossing Limited
Form 10-K for Fiscal Year Ended December 31, 2008
Filed March 4, 2009
File No. 1-16201
Dear Mr. Spirgel:
We have set forth below the response of Global Crossing Limited (the "Company") to the comments contained in the letter of the Staff of the Division of Corporate Finance (the "Staff") of the Securities and Exchange Commission (the "Commission") dated December 15, 2009 with respect to the Company's Form 10-K for the fiscal year ended December 31, 2008, filed on March 4, 2009. For your convenience, we have repeated the Staff's comments before each response.
Form 10-K for Fiscal Year Ended December 31, 2008
Item 7. Management's Discussion and Analysis of Financial Condition and Results of Operations, page 51
Liquidity and Capital Resources, page 71
Financial Condition and State of Liquidity, page 71
1. We note your disclosure at page 73 regarding the legal and contractual restrictions which affect your subsidiaries' ability to make intercompany funds transfers, as well as your discussion at page F-17 of the currency exchange environment in Venezuela. In light of these restrictions, expand your disclosure in future filings to comply with the requirements of Rule 4-08(e)(3)(ii) of Regulation S-X, if applicable. In addition, tell us how you determined that it was not necessary for you to provide condensed parent company financial information and other data in a financial statement schedule, in accordance with Rule 12-04 of Regulation S-X.
Response: As of December 31, 2008, the Company's Venezuelan subsidiary represented 5% of consolidated assets and 2% of consolidated liabilities. These percentages have not varied significantly over time. Our process for considering the requirements of Rule 12-04 of Regulation S-X was influenced by the relatively small size of this subsidiary. Upon receipt of the Staff's comment on this matter we have undertaken a more complete evaluation of the requirements, including the Staff's interpretation on application of the rule in situations like ours where the parent company is in a negative net asset position. Accordingly, the disclosures required by Rule 4-08(e)(3)(ii) and Rule 12-04 of Regulation S-X will now be included in all future filings to the extent applicable, commencing with the Company's Form 10-K for the fiscal year ended December 31, 2009.
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The Company acknowledges that:
If you have any questions, please feel free to contact the undersigned at (973) 937-0333.
Very truly yours,
/s/ John A. Kritzmacher___________
Name: John A. Kritzmacher
Title: EVP and Chief Financial Officer
cc: Michael Rescoe, Audit Committee Chairman
John J. Legere, CEO
