[[China Telecom Corporation Limited Letterhead] September 14, 2011 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, 2010 (File No. 001-31517) Dear Mr. Spirgel: Staff Commission Company Form 20-F This is in response to the comment]
[Page 1.1 2011 Interim Report, dated August 23, 2011. A-1 our business and operating strategies and our ability to successfully execute these strategies;]
[Page 1.1 2011 Interim Report, dated August 23, 2011. A-1 our business and operating strategies and our ability to successfully execute these strategies;]
[Page 1.1 Announcement of Interim Results for the Six Months ended June 30, 2011, dated August 23, 2011. A-1 1.2 Reconciliation of (1) Profit Attributable to Equity Holders (Excluding Amortization of Upfront Connection Fees) to Profit Attributable to Equity Holders, and (2) Earnings before Interest, Tax, Depreciation and Amortization (EBITDA) (Excluding CDMA Network Capacity Lease Fee and Amortization of Upfront]
[Page 1.1 Announcement of Interim Results for the Six Months ended June 30, 2011, dated August 23, 2011. A-1 1.2 Reconciliation of (1) Profit Attributable to Equity Holders (Excluding Amortization of Upfront Connection Fees) to Profit Attributable to Equity Holders, and (2) Earnings before Interest, Tax, Depreciation and Amortization (EBITDA) (Excluding CDMA Network Capacity Lease Fee and Amortization of Upfront]
[Page 1.1 Announcement of 2011 Interim Results, dated August 18, 2011 A-1 2.1 Closure of Register of Members and Announcement in Relation to the Withholding and Payment of Enterprise Income Tax for Non-Resident Enterprises in Respect of 2011 Interim Dividend, dated August 18, 2011 B-1]
[Page 1.1 Announcement of 2011 Interim Results, dated August 18, 2011 A-1 2.1 Closure of Register of Members and Announcement in Relation to the Withholding and Payment of Enterprise Income Tax for Non-Resident Enterprises in Respect of 2011 Interim Dividend, dated August 18, 2011 B-1]
[Number Page 1.1 Announcement, dated August 12, 2011 A-1 -2-]
