Mitel Networks Corporation
350 Legget Drive
Ottawa, Ontario, Canada
K2K 2W7
April 7, 2015
VIA EDGAR
Carlos Pacho
Senior Assistant Chief Accountant
Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
| Re: | Mitel Networks Corporation |
Form 10-K for Fiscal Year Ended December 31, 2014
Filed February 26, 2015
File No. 1-34699
Dear Mr. Pacho:
Mitel Networks Corporation (the “Company”) hereby acknowledges receipt of the comment letter dated March 24, 2015 (the “Comment Letter”) from the staff of the Securities and Exchange Commission concerning the above captioned Form 10-K.
The Company intends to file its written response to the Comment Letter no later than April 21, 2015. Please contact Stephen C. Centa at (416) 504-0527 or Adam M. Givertz at (416) 504-0525, in each case of Paul, Weiss, Rifkind, Wharton & Garrison LLP, should you have any questions or comments regarding this letter.
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| Very truly yours, |
| /S/ Steven E. Spooner |
Steven E. Spooner Chief Financial Officer Mitel Networks Corporation |
| cc: | Adam M. Givertz, Esq. |
Paul, Weiss, Rifkind, Wharton & Garrison LLP
