Exhibit 99.1

                              Horizon Telcom, Inc.
                               68 East Main Street
                             Chillicothe, Ohio 45601

                                                                January 28, 2005

United States Securities and
   Exchange Commission
450 5th Street, N.W.
Washington, D.C. 20549

                  Re:   Schedule 14A (File No. 0-32617)/
                        Schedule 13E-3 (File No. 5-80225)
                        ---------------------------------

Ladies and Gentlemen:

      Reference  is made to the  letter  dated  January  21,  2005  from  Pamela
Carmody,  Special  Counsel - Office of Mergers  and  Acquisitions  at the United
States  Securities  and  Exchange  Commission  ("SEC")  to  Daniel A.  Etna.  As
requested pursuant to such letter,  please be advised that Horizon Telcom, Inc.,
an Ohio corporation (the "Company"),  hereby  acknowledges that: (i) the Company
is  responsible  for  the  adequacy  and  accuracy  of  the  disclosure  in  the
above-referenced filings (the "Filings");  (ii) SEC staff comments or changes to
disclosure in response to SEC staff comments in the Filings  reviewed by the SEC
staff do not  foreclose  the SEC from  taking  any  action  with  respect to the
Filings; and (iii) the Company may not assert SEC staff comments as a defense in
any proceeding  initiated by the SEC or any person under the federal  securities
laws of the United States of America.

                                        Very truly yours,

                                        Horizon Telcom, Inc.

                                        By: /s/ Thomas McKell
                                            -----------------
                                            Thomas McKell
                                            President