October 3, 2019

David Melcon
Chief Financial Officer and Investor Relations Officer
Telefonica Brasil S.A.
Av. Eng  Lu s Carlos Berrini, 1376 - 28  andar
S o Paulo, S.P.
Federative Republic of Brazil

       Re: Telefonica Brasil S.A.
           Form 20-F for the Year Ended December 31, 2018
           Filed February 21, 2019
           Response Letter Filed August 1, 2019
           File No. 001-14475

Dear Mr. Melcon:

       We have reviewed your August 1, 2019 response to our comment letter and
have the
following comments. In some of our comments, we may ask you to provide us with
information
so we may better understand your disclosure.

       Please respond to these comments within ten business days by providing
the requested
information or advise us as soon as possible when you will respond. If you do
not believe our
comments apply to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to these comments, we may have additional
comments. Unless we note otherwise, our references to prior comments are to
comments in our
July 19, 2019 letter.

Form 20-F for the Year Ended December 31, 2018

Item 8. Financial Information
Legal Proceedings (Civil Claims), page 99

1.     We note your response to our prior comment one. Since the matter is
still in dispute and
       may have a significant effect on your financial position or
profitability, please disclose all
       the material facts and developments relating to the suit including the
R$47 billion dollar
       preliminary estimate in accordance with Item 8.A.7 of Form 20-F.
 David Melcon
Telefonica Brasil S.A.
October 3, 2019
Page 2
19) Provisions and Contingencies
c,3,2) Civil contingencies assessed as possible losses, page F-40

2.     We note your response to comment two. Please expand your disclosure to
address the
       significant management judgments and estimation uncertainty with respect
to the amount
       you recorded as a provision for the Preseverance case. Disclose how and
why the
       damages claimed in the Perseverance case (based on the recent expert
report
       commissioned by the trial court) differ significantly from your internal
estimate. Refer to
       paragraphs 122 and 125 of IAS 1.



      You may contact Kathryn Jacobson, Senior Staff Accountant at (202)
551-3365 or Inessa
Kessman, Senior Staff Accountant at (202) 551-3371 if you have questions.



                                                             Sincerely,
FirstName LastNameDavid Melcon
                                                             Division of
Corporation Finance
Comapany NameTelefonica Brasil S.A.
                                                             Office of
Technology
October 3, 2019 Page 2
cc:       Investor Relations
FirstName LastName