United States Cellular Corporation
8410 West Bryn Mawr Avenue
Chicago, IL 60631
773-399-8900
Fax: 773-399-8936
VIA EDGAR
August 16, 2013
Mr. Larry Spirgel
Assistant Director
Securities and Exchange Commission
100 F. Street, N.E.
Mail Stop 3720
Washington, D.C. 20549
Re: United States Cellular Corporation
Form 10-K for the Year ended December 31, 2012
Filed February 26, 2013
Response dated June 7, 2013
File no. 1-9712
Dear Mr. Spirgel:
This letter responds to the oral conversation on August 8, 2013 between Kathryn Jacobson, Securities and Exchange Commission (“SEC” or “Staff”) Senior Staff Accountant, and Douglas Shuma, U.S Cellular’s Chief Accounting Officer, regarding the Staff’s comments on the above-referenced filings.
In response to Ms. Jacobson’s comment to describe for the Staff the disclosure the company would make to describe why it has only one asset group, in future filings U.S. Cellular will include the following disclosure in the notes to its financial statements.
U.S. Cellular has concluded that it has one asset group for purposes of assessing property, plant and equipment for impairment. This conclusion is based on the fact that the individual operating markets are reliant on centrally operated data centers, mobile telephone switching offices, a network operations center and a wide-area network. As a result, U.S. Cellular operates a single integrated national wireless network which represents the lowest level of identifiable cash flows.
In connection with responding to the Staff’s comments, the Company acknowledges that
· the Company is responsible for the adequacy and accuracy of the disclosure in the filings;
· Staff comments or changes to disclosure in response to Staff comments do not foreclose the Commission from taking any action with respect to the filings; and
· the Company may not assert Staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
The Company’s management has reviewed the above responses to the Staff’s comments with the Audit Committee of its Board of Directors. If you have any questions, please contact me at (773) 399-4850 or Douglas D. Shuma, Chief Accounting Officer, at (773) 355-3400.
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| Sincerely, |
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| United States Cellular Corporation | ||||
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| By: |
| /s/ Steven T. Campbell | ||
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| Steven T. Campbell | ||
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| Executive Vice President-Finance, | ||
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| Chief Financial Officer and | |
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| Treasurer |
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cc: |
| Douglas D. Shuma |
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