UNITED STATES

SECURITIES AND EXCHANGE COMMISSION

WASHINGTON, D.C. 20549

DIVISION OF CORPORATION FINANCE

Joel T. May Jones Day jtmay@jonesday.com

Re: Verizon Communications Inc.

Dear Mr. May:

February 3, 2014

This is in regard to your letter dated February 3, 2014 concerning the shareholder proposal submitted by Harrington Investments, Inc. on behalf of Neil Maizlish for inclusion in Verizon's proxy materials for its upcoming annual meeting of security holders. Your letter indicates that the proponent has withdrawn the proposal and that Verizon therefore withdraws its December 27, 2013 request for a no-action letter from the Division. Because the matter is now moot, we will have no further comment.

Copies of all of the correspondence related to this matter will be made available on our website at htq?://www.sec.gov/divisions/comfin/cf-noaction/14a-8.shtml. For your reference, a brief discussion of the Division's informal procedures regarding shareholder proposals is also available at the same website address.

cc: John C. Harrington Harrington Investments, Inc. john@harringtoninvestments.com

Sincerely,

EvanS. Jacobson Special Counsel

JONES DAY

1420 PEACHTREE STREET. N.E. SUITE 800 ATLANTA, GEORGIA 30309.3053

TELEPHONE: + 1.404.521 .3939 FACSIMILE: +I .404.581.8330

JP219180 February 3, 2014

Via Email (shareholdemroposals@sec.gov)

U.S. Securities and Exchange Commission Division of Corporation Finance Office of Chief Counsel 100 F Street, N.E. Washington, D.C. 205049

DIRECT NUMBER: (404) 581-8967 JTMAYOJONESDAY.COM

Re: Verizon Communications Inc.- Withdrawal ofNo-Action Request Dated December 27,2013 Regarding Shareholder Proposal Entitled "Engaging the Board of Directors to Protect Americans' Civil Rights"

Ladies and Gentlemen:

We refer to our letter dated December 27, 2013 (the ''No-Action Request") pursuant to which we requested on behalf of our client Verizon Communications Inc., a Delaware corporation (the "Company"), that the staff of the Division of Corporation Finance (the "Staff') of the U.S. Securities and Exchange Commission (the "Commission") concur with the Company's view that the shareholder proposal entitled ''Engaging the Board of Directors to Protect Americans' Civil Rights" (the "Proposal") submitted by Harrington Investments, Inc. ("Harrington"), on behalf ofNeil Maizlish (the "Proponent"), may be properly omitted pursuant to Rule 14a-8(i}(10}, Rule 14a-8(i)(7) and Rule 14a-8(i)(3) from the proxy materials to be distributed by the Company in connection with its 2014 annual meeting of shareholders.

Attached hereto as Exhibit A are communications from Harrington, who is authorized by the Proponent to act on his behalf, and the Proponent, including an email from the Proponent, dated February 1, 2014, stating that he is withdrawing the Proposal (the "Communications"). In reliance upon the Communications, we accordingly hereby withdraw on behalf of the Company the No-Action Request. If you have any questions with regard to this matter, please feel free to contact us at mary .I. weber@verizon.com or jtmay@jonesday .com.

Enclosures

cc: Mary Louise Weber, Verizon Communications Inc. John C. Harrington, Ha"ington Investments, Inc. Sanford J. Lewis

Sincere!y,

ALKHOBAR AMSTERDAM ATLANTA BEIJING BOSTON BRUSSELS CHICAGO CLEVELAND COLUMBUS DALLAS

DUBAI DOSSELDORF FRANKFURT HONG KONG HOUSTON IRVINE JEDDAH LONDON LOS ANGELES MADRID

MEXICO CITY MIAMI MILAN MOSCOW MUNICH NEW YORK PARIS PITTSBURGH RIYADH SAN DIEGO

SAN FRANCISCO SAO PAULO SHANGHAI SILICON VALLEY SINGAPORE SYDNEY TAIPEI TOKYO WASHINGTON

EXHIBIT A

Subject: Withdrawal Authorization for Verizon Resolution From:

:~~ Neil Maizlish 02/01/2014 07:58PM To: jtmay Cc: "Virginia Cao", sanfordlewis, "John Harrington" Hide Details From: "Neil Maizlish" To: , Cc: "Virginia Cao" ,