CHA [CHINA TELECOM] CORRESP: (Original Filing)

[September 11, 2012 Mr. Larry Spirgel, Assistant Director, Mail Stop 3720, Division of Corporation Finance, 100 F Street, N.E., Re: China Telecom Corporation Limited Annual Report on Form 20-F for the Fiscal Year ended December 31, 2011 (File No. 001-31517) Dear Mr. Spirgel: For your convenience, the Company has included the Staff comments in this response letter in italicized form]

CHA [CHINA TELECOM] CORRESP: September 11, 2012 Mr. Larry Spirgel, Assistant Director,

[September 11, 2012 Mr. Larry Spirgel, Assistant Director, Mail Stop 3720, Division of Corporation Finance, 100 F Street, N.E., Re: China Telecom Corporation Limited Annual Report on Form 20-F for the Fiscal Year ended December 31, 2011 (File No. 001-31517) Dear Mr. Spirgel: For your convenience, the Company has included the Staff comments in this response letter in italicized form]

CHA [CHINA TELECOM] 6-K: Page 1.1 Circular of (1) Major Transaction and

[Page 1.1 Circular of (1) Major Transaction and Connected Transaction in respect of the Acquisition of Certain CDMA Network Assets and Associated Liabilities and (2) Renewal of Existing Continuing Connected Transactions, dated August 30, 2012 A-1 1.2 2012 Interim Report, dated August 22, 2012 B-1 • our business and operating strategies and our ability to successfully execute these strategies; •]

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CHA [CHINA TELECOM] 6-K: (Original Filing)

[Page 1.1 Circular of (1) Major Transaction and Connected Transaction in respect of the Acquisition of Certain CDMA Network Assets and Associated Liabilities and (2) Renewal of Existing Continuing Connected Transactions, dated August 30, 2012 A-1 1.2 2012 Interim Report, dated August 22, 2012 B-1 • our business and operating strategies and our ability to successfully execute these strategies; •]

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CHA [CHINA TELECOM] 6-K: (Original Filing)

[Number Page 1.1 Announcement of Major Transaction and Connected Transaction in respect of the Acquisition of Certain CDMA Network Assets and Associated Liabilities, dated August 22, 2012 A-1 1.2 Announcement of Interim Results for the Six Months ended June 30, 2012, dated August 22, 2012]

CHA [CHINA TELECOM] 6-K: Number Page 1.1 Announcement of Major Transaction and

[Number Page 1.1 Announcement of Major Transaction and Connected Transaction in respect of the Acquisition of Certain CDMA Network Assets and Associated Liabilities, dated August 22, 2012 A-1 1.2 Announcement of Interim Results for the Six Months ended June 30, 2012, dated August 22, 2012]

CHA [CHINA TELECOM] CORRESP: (Original Filing)

[[China Telecom Letter Head] July 26, 2012 Mr. Larry Spirgel, Assistant Director, Mail Stop 3720, Division of Corporation Finance, 100 F Street, N.E., Re: China Telecom Corporation Limited Annual Report on Form 20-F for the Fiscal Year ended December 31, 2011 (File No. 001-31517) Dear Mr. Spirgel: For your convenience, the Company has included the Staff comments in this response]

CHA [CHINA TELECOM] CORRESP: [China Telecom Letter Head] July 26, 2012 Mr.

[[China Telecom Letter Head] July 26, 2012 Mr. Larry Spirgel, Assistant Director, Mail Stop 3720, Division of Corporation Finance, 100 F Street, N.E., Re: China Telecom Corporation Limited Annual Report on Form 20-F for the Fiscal Year ended December 31, 2011 (File No. 001-31517) Dear Mr. Spirgel: For your convenience, the Company has included the Staff comments in this response]

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