Securities Exchange Act of 1934
Rule 12g-3

March 20, 2008

Response of the Office of International Corporate Finance
Division of Corporation Finance

Based on the facts presented, the Division's views are as follows. Capitalized terms have the same meanings defined in your letter.

The T-R PLC Shares, including those represented by T-R PLC ADSs, issued to Reuters Securityholders in the Transaction shall be deemed registered under the Exchange Act by operation of Rule 12g-3(c). We understand T-R PLC will indicate the T-R PLC Shares are registered under Section 12(b) of the Exchange Act by a Report of Foreign Issuer on Form 6-K furnished to the Commission in connection with the Transaction.

After completion of the Transaction, employees of T-R PLC and its subsidiaries may be treated as employees of T-R Corp and employees of T-R Corp and its subsidiaries may be treated as employees of T-R PLC, for the purpose of any registration statement on Form S-8 that may be filed jointly by T-R Corp and T-R PLC to register the issuance of T-R Corp Shares or T-R PLC Shares to them pursuant to the Thomson- Reuters Plans.

After completion of the Transaction, T-R PLC may include the prior activities and status of Reuters in determining whether T-R PLC meets the eligibility requirements for the use of Forms F-3, F-4 and S-8.

After completion of the Transaction, T-R PLC may include the prior reporting history of Reuters in determining whether it has complied with the public information requirements of Rule 144(c)(1) under the Securities Act.

After completion of the Transaction, T-R PLC may be treated as an issuer subject to the reporting requirements of the Exchange Act for purposes of the Rule 174(b) exemption from the prospectus delivery requirements of Section 4(3) of the Securities Act.

These positions are based on the representations made to the Division in your letter. Any different facts or conditions might require different conclusions.

Incoming Letter:

The Incoming Letter is in Acrobat format.

http://www.sec.gov/divisions/corpfin/cf-noaction/2008/reuters032008-12g-3.htm