August 19, 2024
David McAtee II
Senior Executive Vice President and General Counsel
AT&T INC.
208 S. Akard St.
Dallas, TX 75202
Re: AT&T INC.
Form 8-K
Filed July 12, 2024
File No. 001-08610
Dear David McAtee II:
We have completed our review of your filing. Please note that:
our decision not to issue additional comments should not be interpreted
to mean that the
Commission staff or the Commission either agree or disagree with, or are
opining on the
legality of, your disclosure or responses, conclusions, or positions you
have taken. Specifically
we note that, despite your conclusion that you did not believe that there
was any material
impact or reasonably likely material impact as a result of the incident,
your response states
that the Company concluded that, particularly with the reputational and
customer perception
risks associated with the incident, information about the incident would
significantly alter the
total mix of information made available and that there was a substantial
likelihood that a
reasonable shareholder would consider information about the incident to be
important in
making a voting or investment decision. We again call your attention to
the Commission s
statement in the adopting release that Item 1.05 s inclusion of
financial condition and results
of operations is not exclusive; companies should consider qualitative
factors alongside
quantitative factors in assessing the material impact of an incident. For
example, consider
impacts on customer relationships, competitiveness, and potential
reputational harm related to
the cybersecurity incident. It appears inconsistent to conclude that an
incident is material
because of reputational and customer perception risks associated with
the incident but that
the incident has not had, and is not reasonably likely to have, any
material impacts on the
company, including with respect to the company s reputation and customer
perception;
the company and its management are responsible for the accuracy and
adequacy of their
disclosures, notwithstanding any review, comments, action or absence of
action by the staff;
and
the completion of our review does not foreclose the Commission from
taking any action with
respect to the filing, the company, or the company s practices.
August 19, 2024
Page 2
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc: Thomas J. Kim, Esq.