-----BEGIN PRIVACY-ENHANCED MESSAGE----- Proc-Type: 2001,MIC-CLEAR Originator-Name: webmaster@www.sec.gov Originator-Key-Asymmetric: MFgwCgYEVQgBAQICAf8DSgAwRwJAW2sNKK9AVtBzYZmr6aGjlWyK3XmZv3dTINen TWSM7vrzLADbmYQaionwg5sDW3P6oaM5D3tdezXMm7z1T+B+twIDAQAB MIC-Info: RSA-MD5,RSA, Flqf0w69GVnY5YSdraPKdu1Z25hEWW2g34UOsJoFjv06z700as2cj+pF65F7mRbj JxlhzGxPthmNqYRm/L6nAQ== 0000950123-09-067587.txt : 20100119 0000950123-09-067587.hdr.sgml : 20100118 20091202152256 ACCESSION NUMBER: 0000950123-09-067587 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20091202 FILER: COMPANY DATA: COMPANY CONFORMED NAME: ALASKA COMMUNICATIONS SYSTEMS GROUP INC CENTRAL INDEX KEY: 0001089511 STANDARD INDUSTRIAL CLASSIFICATION: TELEPHONE COMMUNICATIONS (NO RADIO TELEPHONE) [4813] IRS NUMBER: 522126573 STATE OF INCORPORATION: DE FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 600 TELEPHONE AVENUE STREET 2: - CITY: ANCHORAGE STATE: AK ZIP: 99503 BUSINESS PHONE: 9072973000 MAIL ADDRESS: STREET 1: 600 TELEPHONE AVENUE STREET 2: - CITY: ANCHORAGE STATE: AK ZIP: 99503 FORMER COMPANY: FORMER CONFORMED NAME: ALEC HOLDINGS INC DATE OF NAME CHANGE: 19990624 CORRESP 1 filename1.htm corresp
December 2, 2009
VIA EDGAR
Mr. Jay H. Knight
Staff Attorney
U.S. Securities and Exchange Commission
Division of Corporation Finance
100 F St. NE
Washington, D.C. 20549
Re:   Alaska Communications Systems Group, Inc.
Form 10-K for Fiscal Year Ended December 31, 2008, as amended
And Document Incorporated by Reference
Filed March 9, 2009
File No. 000-28167
Dear Mr. Knight,
               Alaska Communications Systems Group, Inc. (the “Company”), provides the following information in response to the comment contained in the correspondence of the staff (the “Staff”) of the U. S. Securities and Exchange Commission (the “Commission”), dated November 23, 2009, relating to the Company’s above-referenced filings (the “Filings”).
               In this letter, we have recited the Staff’s comments in bold type and have followed each comment with the Company’s response.
Definitive Proxy Statement Incorporated By Reference into Part III of Form 10-K
Compensation Discussion and Analysis, page 13 of the Proxy Statement
  1.   We note your response to comment two in our letter dated November 5, 2009, regarding the disclosure of 2008 performance targets. In a response letter, please disclose to us the 2008 Company Performance Targets upon which the annual cash incentive awards were based. Also, confirm your intention to disclose all material 2009 Company Performance Targets in your next Form 10-K or definitive proxy statement incorporated by reference (e.g., targets related to liquidity and EBITDA). In this regard, we note that your prior response qualifies your confirmation of compliance in future filings by retaining your right to elect not to disclose such information in accordance with Instruction 4 to Item 402(b).
               In response to the Staff’s comments, the Company discloses that the 2008 Company Performance Target was an EBITDA less maintenance capital expenditures measure of $90 million, for the year ended December 31, 2008, which amount formed the basis of the annual cash incentive awards to named executive officers for 2008 performance.
               In further response to the Staff’s comments, the Company confirms that it intends to disclose all material 2009 Company Performance Targets, including those targets related to liquidity and EBITDA, in its next Form 10-K or definitive proxy statement incorporated by reference.
               Thank you again for your assistance.
         
  Very truly yours,


ALASKA COMMUNICATIONS SYSTEMS GROUP, INC.
 		  
  /s/ David Wilson    
  David Wilson   
  Executive Vice President and Chief Financial Officer   
 
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