October 14, 2014
Via EDGAR
Mr. Larry Spirgel
Assistant Director
Division of Corporation Finance
Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
United States of America
| Re: | Philippine Long Distance Telephone Company |
Annual Report on Form 20-F for the Fiscal Year ended December 31, 2013
filed April 2, 2014, 2006 (File No. 1- 03006)
Dear Mr. Spirgel:
Philippine Long Distance Telephone Company (the “Company”) has received a comment letter from the staff of the Division of Corporation Finance (the “Staff”), dated September 30, 2014. The comment letter is related to the Company’s Annual Report on Form 20-F for the fiscal year ended December 31, 2013 (the “Form 20-F”), which was filed with the United States Securities and Exchange Commission on April 2, 2014. We wish to thank you and the other members of the Staff for providing us with your comments.
The Company notes that the Staff has requested that the Company either (i) respond to the Staff’s comments within 10 business days or (ii) inform the Staff as to when the Company will provide a response to the comments. The Company has carefully reviewed and considered the Staff’s comments and is in the process of preparing a response to the comments. The Company will provide its response to the Staff’s comments by October 31, 2014.
Thank you again for your time. Please feel free to contact Michael G. DeSombre of Sullivan & Cromwell (tel: (+852) 2826-8696; fax (+852) 2826-1774; e-mail: desombrem@sullcrom.com), or the undersigned by phone at (+632) 816-8553 or by e-mail at lrchan@pldt.com.ph, with any questions you may have.
| Sincerely, |
| /s/ Ma. Lourdes C. Rausa-Chan |
| MA. LOURDES C. RAUSA-CHAN |
| Senior Vice President, Corporate Affairs and Legal Services Head and Corporate Secretary |
| cc: | Terry French, Accounting Branch Chief |
Kathleen Krebs, Special Counsel
Christy Adams, Senior Staff Accountant
(Securities and Exchange Commission)
Napoleon L. Nazareno, President and Chief Executive Officer
Anabelle Lim-Chua, Senior Vice President and Treasurer
June Cheryl A. Cabal-Revilla, First Vice President and Controller
(Philippine Long Distance Telephone Company)
Michael G. DeSombre
Ram Narayan
Paul E. Hubble
(Sullivan & Cromwell)
