[Shearman & Sterling LLP Letterhead] george.spera@shearman.com October 19, 2007 212-848-7636 BY EDGAR AND FEDERAL EXPRESS - ---------------------------- Kathleen Krebs Division of Corporation Finance United States Securities and Exchange Commission 100 F Street, N.E. Washington, D.C. 20549 Re: Viacom Inc. Definitive Schedule 14A Filed April 20, 2007 File No. 001-32686 Dear Ms. Krebs: On behalf of our client, Viacom Inc. ("Viacom"), I would like to confirm our telephone conversation of yesterday afternoon in which I conveyed to you Viacom's undertaking to respond during the week of November 5, 2007 to the comments set forth in your letter dated September 27, 2007 on the above-referenced filing. We appreciate your having agreed to this schedule. I also request on behalf of Viacom that any future correspondence on this or any other matters be directed to: Michael D. Fricklas Executive Vice President, General Counsel and Secretary Viacom Inc. 1515 Broadway New York, NY 10016 If you have any questions concerning the matters referred to in this letter, please call me at (212) 848-7636. Sincerely, /s/ George Spera - ---------------- cc: Michael D. Fricklas, Viacom Inc. Allison S. Gray, Viacom Inc. Linda E. Rappaport, Shearman & Sterling LLP