Level 3 Communications, Inc.

1025 Eldorado Boulevard

Broomfield, CO 80021

VIA EDGAR

September 15, 2014

United States Securities and Exchange Commission

Division of Corporation Finance

100 F Street, NE

Mail Stop 3720

Washington, D.C. 20549

Attn: Terry French, Accountant Branch Chief

Re: Level 3 Communications, Inc.

Form 10-K for the Year Ended December 31, 2013

Filed February 27, 2014

File No. 001-35134

Dear Mr. French:

On September 4, 2014, the SEC provided verbal comments with respect to Level 3 Communications, Inc.'s supplemental response dated September 2, 2014 in relation to the Company’s Form 10-K for the year ended December 31, 2013. For your convenience, we have included a summary of the Staff's comment in italics below and have provided our response as well. References in this letter to the “Company” are references to Level 3 Communications, Inc., and its consolidated subsidiaries unless the context states otherwise.

Selling, General and Administrative, page 80

1. Please provide supplementally, a SAB 99 materiality analysis supporting the allocation of Selling, General and Administrative Expenses between Network Related Expenses and Selling, General and Administrative Expenses.

Response: The Company is providing the analysis requested supplementally.

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As requested by the Staff, we acknowledge:

• The Company is responsible for the adequacy and accuracy of the disclosure in the Form 10-K for the year ended December 31, 2013;

• Staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the foregoing filing; and

• We 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.

We have sought to respond to all of your comments. If you have any further comments that you would like to have addressed, please let us know. If you have any questions, you may contact the undersigned at (720) 888-8286 or Neil Eckstein, Senior Vice President, Assistant General Counsel and Assistant Secretary at (720) 888-2514.

Sincerely,

/s/ Eric J. Mortensen

Eric J. Mortensen

Senior Vice President and Controller

Principal Accounting Officer

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