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]

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