CHA [CHINA TELECOM] CORRESP: (Original Filing)

[September 28, 2009 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, 2008 (File No. 001-31517) Dear Mr. Spirgel: Staff SEC Company Form 20-F This is in response to the comment letter from the staff (the]

CHA [CHINA TELECOM] CORRESP: September 28, 2009 Mr. Larry Spirgel, Assistant Director,

[September 28, 2009 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, 2008 (File No. 001-31517) Dear Mr. Spirgel: Staff SEC Company Form 20-F This is in response to the comment letter from the staff (the]

CHA [CHINA TELECOM] CORRESP: (Original Filing)

[September 22, 2009 Via Facsimile and EDGAR Mr. Larry Spirgel Assistant Director Mail Stop 3720 Division of Corporation Finance 100 F Street, N.E. Facsimile: (+1-703) 813-6986 Re: China Telecom Corporation Limited Annual Report on Form 20-F for the Fiscal Year ended December 31, 2008 (File No. 001-31517) Dear Mr. Spirgel: Company Form 20-F China Telecom Corporation Limited (the “ The]

CHA [CHINA TELECOM] CORRESP: September 22, 2009 Via Facsimile and EDGAR Mr.

[September 22, 2009 Via Facsimile and EDGAR Mr. Larry Spirgel Assistant Director Mail Stop 3720 Division of Corporation Finance 100 F Street, N.E. Facsimile: (+1-703) 813-6986 Re: China Telecom Corporation Limited Annual Report on Form 20-F for the Fiscal Year ended December 31, 2008 (File No. 001-31517) Dear Mr. Spirgel: Company Form 20-F China Telecom Corporation Limited (the “ The]

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

[Page 1.1 Announcement of Interim Results for the Six Months ended June 30, 2009, dated August 27, 2009. A-1 1.2 Reconciliation of Earnings before Interest, Tax, Depreciation and Amortization (“EBITDA”) (Excluding CDMA Network Capacity Lease Fee) to Net Cash from Operating Activities, dated August 27, 2009. B-1 2]

CHA [CHINA TELECOM] 6-K: Page 1.1 Announcement of Interim Results for the

[Page 1.1 Announcement of Interim Results for the Six Months ended June 30, 2009, dated August 27, 2009. A-1 1.2 Reconciliation of Earnings before Interest, Tax, Depreciation and Amortization (“EBITDA”) (Excluding CDMA Network Capacity Lease Fee) to Net Cash from Operating Activities, dated August 27, 2009. B-1 2]

CHA [CHINA TELECOM] 20-F: (Original Filing)

[Title of Each Class Name of Each Exchange On Which Registered American depositary shares H shares, par value RMB1.00 per share * None (Title of Class) None (Title of Class) Indicate the number of outstanding shares of each of the issuer’s classes of capital or common stock as of the close of the period covered by the annual report. x] [ARTICLES OF ASSOCIATION OF CHINA TELECOM CORPORATION LIMITED (Amended at the 2009 first extraordinary general meeting held on March 12, 2009) CONTENTS CLAUSE PAGE CHAPTER 1: GENERAL PROVISIONS 1 CHAPTER 2: THE COMPANY’S OBJECTIVES AND SCOPE OF BUSINESS 3 CHAPTER 3: SHARES AND REGISTERED CAPITAL 4 CHAPTER 4: REDUCTION OF CAPITAL AND REPURCHASE OF SHARES 7 CHAPTER 5: FINANCIAL ASSISTANCE] [English Summary of Supplemental Agreement to the Interconnection Settlement Agreement Between China Telecom Corporation Limited and China Telecommunications Corporation China Telecommunications Corporation (“Party A”) and China Telecom Corporation Limited (“Party B”) entered into the Interconnection Settlement Agreement on September 10, 2002 and renewed the agreement on August 30, 2006 and December 31, 2008. Party A and Party B entered into] [English Summary of Supplemental Agreement to the IT Services Framework Agreement Between China Telecom Corporation Limited and China Telecommunications Corporation China Telecom Corporation Limited (“Party A”) and China Telecommunications Corporation (“Party B”) entered into the IT Services Framework Agreement on August 30, 2006. Party A and Party B entered into the Supplemental Agreement to the IT Services Framework Agreement (the] [English Summary of Supplemental Agreement to the Supplies Procurement Services Framework Agreement Between China Telecom Corporation Limited and China Telecommunications Corporation China Telecom Corporation Limited (“Party A”) and China Telecommunications Corporation (“Party B”) entered into the Supplies Procurement Services Framework Agreement on August 30, 2006. Party A and Party B entered into the Supplemental Agreement to the Supplies Procurement Services] [English Summary of Supplemental Agreement to the Engineering Framework Agreement Between China Telecom Corporation Limited and China Telecommunications Corporation China Telecom Corporation Limited (“Party A”) and China Telecommunications Corporation (“Party B”) entered into the Engineering Framework Agreement on August 30, 2006. Party A and Party B entered into the Supplemental Agreement to the Engineering Framework Agreement (the “Supplemental Agreement”) on] [English Summary of Supplemental Agreement to the Community Services Framework Agreement Between China Telecom Corporation Limited and China Telecommunications Corporation China Telecom Corporation Limited (“Party A”) and China Telecommunications Corporation (“Party B”) entered into the Community Services Framework Agreement on August 30, 2006. Party A and Party B entered into the Supplemental Agreement to the Community Services Framework Agreement (the] [English Summary of Supplemental Agreement to the Ancillary Telecommunications Services Framework Agreement Between China Telecom Corporation Limited and China Telecommunications Corporation China Telecom Corporation Limited (“Party A”) and China Telecommunications Corporation (“Party B”) entered into the Ancillary Telecommunications Services Framework Agreement on August 30, 2006. Party A and Party B entered into the Supplemental Agreement to the Ancillary Telecommunications Services] [China Telecom Corporation Limited And China Telecommunications Corporation CDMA Network Capacity Lease Agreement this Agreement This CDMA Network Capacity Lease Agreement (“ (ii) China Telecommunications Corporation, a state-owned enterprise incorporated on May 17, 2000 under the laws of the PRC, the controlling shareholder of China Telecom Corporation Limited, with its main business being making investment and holding controlling interests mainly] [English Summary of Agreement for Transfer of CDMA Business Among China Unicom Corporation Limited and China Unicom Limited and China Telecom Corporation Limited China Telecom Corporation Limited (the “Company”), China Unicom Corporation Limited (“CUCL”) and China Unicom Limited (“Unicom”, together with CUCL, the “Unicom Group”), jointly the parties, entered into an Agreement for Transfer of CDMA Business (the “Acquisition Agreement”)] [China Telecom Corporation Limited And China Telecom Group Beijing Corporation Merger Agreement November 14 th , 2008 This agreement is signed by the following two parties in Beijing, P.R.C. on November 14 th , 2008: The Merging Party: The Merged Party Whereas, 1. To optimize the organizational structure and promote the core competitiveness of the company, and based on the] [English Summary of Supplemental Agreement to the Optic Fiber Leasing Agreement Between China Telecom Corporation Limited and China Telecommunications Corporation China Telecommunications Corporation (“Party A”) and China Telecom Corporation Limited (“Party B”) entered into the Ancillary Telecommunications Services Framework Agreement on September 10, 2002. Party A and Party B entered into the Supplemental Agreement to the Optic Fiber Leasing Agreement] [English Summary of Underwriting Agreement regarding Medium Term Notes of China Telecom Corporation Limited in 2008 Among China Telecom Corporation Limited and Industrial and Commercial Bank of China Limited and CITIC Securities Company Limited China Telecom Corporation Limited (“Party A”), Industrial and Commercial Bank of China Limited (“Party B”) and CITIC Securities Company Limited (“Party C”) entered into an underwriting] [English Summary of Underwriting Agreement regarding the First Tranche of Short-Term Commercial Paper of China Telecom Corporation Limited in 2008 Among China Telecom Corporation Limited and Bank of Communications Co., Ltd. and China Development Bank China Telecom Corporation Limited, as the issuer, Bank of Communications Co., Ltd., as the lead underwriter, and Bank of Communications Co., Ltd., as the joint] [List of Subsidiaries Name Jurisdiction of Incorporation China Telecom Group Yellow Pages Information Company Ltd. The People’s Republic of China China Telecom Best Tone Information Service Co., Limited The People’s Republic of China China Telecom System Integration Co., Limited The People’s Republic of China Navict (Beijing) Information Consulting Co., Ltd. The People’s Republic of China Tianyi Telecom Terminals Company Limited] [Certification I, Wang Xiaochu, certify that: 1. I have reviewed this annual report on Form 20-F of China Telecom Corporation Limited (the “Company”); 2. Based on my knowledge, this annual report does not contain any untrue statement of a material fact or omit to state a material fact necessary to make the statements made, in light of the circumstances under] [Certification I, Wu Andi, certify that: 1. I have reviewed this annual report on Form 20-F of China Telecom Corporation Limited (the “Company”); 2. Based on my knowledge, this annual report does not contain any untrue statement of a material fact or omit to state a material fact necessary to make the statements made, in light of the circumstances under] [Certification Wang Xiaochu Chief Executive Officer] [Certification Wu Andi Chief Financial Officer]

CHA [CHINA TELECOM] 20-F: Title of Each Class Name of Each Exchange

[Title of Each Class Name of Each Exchange On Which Registered American depositary shares H shares, par value RMB1.00 per share * None (Title of Class) None (Title of Class) Indicate the number of outstanding shares of each of the issuer’s classes of capital or common stock as of the close of the period covered by the annual report. x] [ARTICLES OF ASSOCIATION OF CHINA TELECOM CORPORATION LIMITED (Amended at the 2009 first extraordinary general meeting held on March 12, 2009) CONTENTS CLAUSE PAGE CHAPTER 1: GENERAL PROVISIONS 1 CHAPTER 2: THE COMPANY’S OBJECTIVES AND SCOPE OF BUSINESS 3 CHAPTER 3: SHARES AND REGISTERED CAPITAL 4 CHAPTER 4: REDUCTION OF CAPITAL AND REPURCHASE OF SHARES 7 CHAPTER 5: FINANCIAL ASSISTANCE] [English Summary of Supplemental Agreement to the Interconnection Settlement Agreement Between China Telecom Corporation Limited and China Telecommunications Corporation China Telecommunications Corporation (“Party A”) and China Telecom Corporation Limited (“Party B”) entered into the Interconnection Settlement Agreement on September 10, 2002 and renewed the agreement on August 30, 2006 and December 31, 2008. Party A and Party B entered into] [English Summary of Supplemental Agreement to the IT Services Framework Agreement Between China Telecom Corporation Limited and China Telecommunications Corporation China Telecom Corporation Limited (“Party A”) and China Telecommunications Corporation (“Party B”) entered into the IT Services Framework Agreement on August 30, 2006. Party A and Party B entered into the Supplemental Agreement to the IT Services Framework Agreement (the] [English Summary of Supplemental Agreement to the Supplies Procurement Services Framework Agreement Between China Telecom Corporation Limited and China Telecommunications Corporation China Telecom Corporation Limited (“Party A”) and China Telecommunications Corporation (“Party B”) entered into the Supplies Procurement Services Framework Agreement on August 30, 2006. Party A and Party B entered into the Supplemental Agreement to the Supplies Procurement Services] [English Summary of Supplemental Agreement to the Engineering Framework Agreement Between China Telecom Corporation Limited and China Telecommunications Corporation China Telecom Corporation Limited (“Party A”) and China Telecommunications Corporation (“Party B”) entered into the Engineering Framework Agreement on August 30, 2006. Party A and Party B entered into the Supplemental Agreement to the Engineering Framework Agreement (the “Supplemental Agreement”) on] [English Summary of Supplemental Agreement to the Community Services Framework Agreement Between China Telecom Corporation Limited and China Telecommunications Corporation China Telecom Corporation Limited (“Party A”) and China Telecommunications Corporation (“Party B”) entered into the Community Services Framework Agreement on August 30, 2006. Party A and Party B entered into the Supplemental Agreement to the Community Services Framework Agreement (the] [English Summary of Supplemental Agreement to the Ancillary Telecommunications Services Framework Agreement Between China Telecom Corporation Limited and China Telecommunications Corporation China Telecom Corporation Limited (“Party A”) and China Telecommunications Corporation (“Party B”) entered into the Ancillary Telecommunications Services Framework Agreement on August 30, 2006. Party A and Party B entered into the Supplemental Agreement to the Ancillary Telecommunications Services] [China Telecom Corporation Limited And China Telecommunications Corporation CDMA Network Capacity Lease Agreement this Agreement This CDMA Network Capacity Lease Agreement (“ (ii) China Telecommunications Corporation, a state-owned enterprise incorporated on May 17, 2000 under the laws of the PRC, the controlling shareholder of China Telecom Corporation Limited, with its main business being making investment and holding controlling interests mainly] [English Summary of Agreement for Transfer of CDMA Business Among China Unicom Corporation Limited and China Unicom Limited and China Telecom Corporation Limited China Telecom Corporation Limited (the “Company”), China Unicom Corporation Limited (“CUCL”) and China Unicom Limited (“Unicom”, together with CUCL, the “Unicom Group”), jointly the parties, entered into an Agreement for Transfer of CDMA Business (the “Acquisition Agreement”)] [China Telecom Corporation Limited And China Telecom Group Beijing Corporation Merger Agreement November 14 th , 2008 This agreement is signed by the following two parties in Beijing, P.R.C. on November 14 th , 2008: The Merging Party: The Merged Party Whereas, 1. To optimize the organizational structure and promote the core competitiveness of the company, and based on the] [English Summary of Supplemental Agreement to the Optic Fiber Leasing Agreement Between China Telecom Corporation Limited and China Telecommunications Corporation China Telecommunications Corporation (“Party A”) and China Telecom Corporation Limited (“Party B”) entered into the Ancillary Telecommunications Services Framework Agreement on September 10, 2002. Party A and Party B entered into the Supplemental Agreement to the Optic Fiber Leasing Agreement] [English Summary of Underwriting Agreement regarding Medium Term Notes of China Telecom Corporation Limited in 2008 Among China Telecom Corporation Limited and Industrial and Commercial Bank of China Limited and CITIC Securities Company Limited China Telecom Corporation Limited (“Party A”), Industrial and Commercial Bank of China Limited (“Party B”) and CITIC Securities Company Limited (“Party C”) entered into an underwriting] [English Summary of Underwriting Agreement regarding the First Tranche of Short-Term Commercial Paper of China Telecom Corporation Limited in 2008 Among China Telecom Corporation Limited and Bank of Communications Co., Ltd. and China Development Bank China Telecom Corporation Limited, as the issuer, Bank of Communications Co., Ltd., as the lead underwriter, and Bank of Communications Co., Ltd., as the joint] [List of Subsidiaries Name Jurisdiction of Incorporation China Telecom Group Yellow Pages Information Company Ltd. The People’s Republic of China China Telecom Best Tone Information Service Co., Limited The People’s Republic of China China Telecom System Integration Co., Limited The People’s Republic of China Navict (Beijing) Information Consulting Co., Ltd. The People’s Republic of China Tianyi Telecom Terminals Company Limited] [Certification I, Wang Xiaochu, certify that: 1. I have reviewed this annual report on Form 20-F of China Telecom Corporation Limited (the “Company”); 2. Based on my knowledge, this annual report does not contain any untrue statement of a material fact or omit to state a material fact necessary to make the statements made, in light of the circumstances under] [Certification I, Wu Andi, certify that: 1. I have reviewed this annual report on Form 20-F of China Telecom Corporation Limited (the “Company”); 2. Based on my knowledge, this annual report does not contain any untrue statement of a material fact or omit to state a material fact necessary to make the statements made, in light of the circumstances under] [Certification Wang Xiaochu Chief Executive Officer] [Certification Wu Andi Chief Financial Officer]

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