CHA [CHINA TELECOM] CORRESP: October 26, 2012 Mr. Larry Spirgel, Assistant Director,
[October 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 letter in italicized form]