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METZGER & McDONALD PLLC

(formerly Prager, Metzger & Kroemer PLLC)

a professional limited liability company

attorneys, mediators & counselors

    Steven C. Metzger

    2626 Cole Avenue, Suite 900

    Direct Dial 214-740-5030

    Dallas, Texas 75204-1083

    Facsimile 214-523-3838

    smetzger@pmklaw.com

    214-969-7600

    214-969-7635

    www.pmklaw.com

August 29, 2005

Via EDGAR, Via Facsimile 202-772-9213

and Via Federal Express

Office of the Chief Accountant

United States Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

    Re:

    CabelTel International Corporation (Commission File
No. 000-18704), CIK No. 0000105744 — Form 10-K for the fiscal year
ended December 31, 2004; Appeal dated July 18, 2005

Ladies and Gentlemen:

     CabelTel International Corporation, formerly Greenbriar Corporation (the “Company”
or “GBR”) entered an appeal with the Office of the Chief Accountant (“OCA”) by letter
dated July 18, 2005 of an issue/conclusion by the Staff of the Securities and Exchange
Commission, Division of Corporation Finance (the “Staff”) relating to the accounting
treatment by the Company of an acquisition occurring in October 2004 and accounted for
as a reverse-acquisition in the December 31, 2004 financial statements of the Company
included in its Form 10-K for the fiscal year ended December 31, 2004. After an
initial telephone conversation with the OCA, followed by a separate telephone call on
August 10, 2005 with the Staff, we understand that OCA wishes to see the Company’s
analysis of paragraph 17 of SFAS. The purpose of this letter is to provide that
analysis. For convenience, various subparts of paragraph 17 of SFAS 141 are restated
below followed in each instance by the applicable analysis for such subpart. Also
included in each response, where appropriate, is a reference to the text of any
applicable document or instrument referenced in that analysis.

     The beginning of paragraph 17 of SFAS 141 states as follows:

     “17. In a business combination effected through an exchange
of equity interests, the entity that issues the equity interests is
generally the acquiring entity. In some business combinations (commonly
referred to as Office of the Chief Accountant United States Securities
and Exchange Commission reverse acquisitions), however, the acquired
entity issues the

Office of the Chief Accountant

United States Securities and Exchange Commission

August 29, 2005

Page 2

equity interests. Commonly, the acquiring entity is
the larger entity. However the facts and circumstances
surrounding a business combination sometimes indicate that a
smaller entity acquires a larger one. In some business combinations, the
combined entity assumes the name of the acquired entity. Thus, in
identifying the acquiring entity in a combination effected through an
exchange of equity interests, all pertinent facts and circumstances
shall be considered, in particular: . . .”

Analysis of Preamble.

     The combination occurred on October 12, 2004, when the Company entered into an
Acquisition Agreement (the “Acquisition Agreement”) with certain individuals (the
“Sellers”), pursuant to which the Company effectively acquired a 74.8% net interest in
the equity of Cable Bulgaria AD, now known as CableTEL AD (“CableTEL AD”), in exchange
for the issuance of 31,500 shares of Series J 2% Preferred Stock which is to be
exchanged into 8,788,500 shares of the Company’s Common Stock (approximately 89% of
what will then be the outstanding shares) upon the completion of certain regulatory
requirements. The acquisition, issuance of preferred stock and the ultimate exchange
into common stock is a single transaction accomplished in a series of steps for
regulatory compliance reasons. It is impossible to separate the steps into separate
transactions because without the exchange into common stock the acquisition will be
rescinded by the Sellers.

     CableTEL AD is a foreign operating company providing cable, internet and
telephone services to the country of Bulgaria. From a size standpoint, CableTEL AD is
clearly “the larger entity” with more assets, more revenues and significantly more
employees than existing GBR. In addition, an independent business valuation firm
valued CableTEL AD ($34,011,000) as being approximately 10 times more valuable than
existing GBR ($3,497,000 based on stock price) at the date of the acquisition. For
additional information on CableTEL AD at the time of the acquisition see Financial
Statements, Businesses Acquired, in the Company’s Current Report on Form 8-K, as
amended, for event report of October 12, 2004.

     At the time of the acquisition, the economic interests of the various participants (including
the Sellers and holders of blocks of Common Stock of the Company) shifted to the Sellers of
CableTEL AD, who as described below, retained or received, by virtue of the acquisition, at least
working control of the Company, if not actual control. Three of the Sellers (Ron Finley, Jeff
Finley and Bradford A. Phillips) had no material relationship with the Company prior to the
acquisition on October 12, 2004. Gene E. Phillips had prior involvement with the Company, and by
virtue of the acquisition and other events, together with the other Sellers and three entities
moved to a level of in excess of 48% of the equity ownership of the Company.

     Subpart (a) of paragraph 17 of SFAS states as follows:

     “(a) The relative voting rights in the combined entity after the
combination — all else being equal, the acquiring entity is the
combining entity whose owners as a group retained or received the larger
portion of the voting rights in the combined entity. In determining
which group of owners retained or received the larger portion of the
voting rights, consideration shall be given to the existence of any
unusual or special voting arrangements and options, warrants, or
convertible securities.”

Office of the Chief Accountant

United States Securities and Exchange Commission

August 29, 2005

Page 3

Factual Analysis of subpart (a).

     As stated above, the Sellers will hold 89% of the outstanding common stock outstanding of the
Company. The issuance of 2% Preferred Stock is an interim step necessary to allow time to comply
with the American Stock Exchange (“AMEX”) requirement that common stock issuances greater than 20%
or preferred stock with conversion features having a similar effect be approved by stockholder vote
or written consent by the requisite number. The Series J 2% Preferred Stock was designed to fall
below that requirement so the Company could close the acquisition in a timely manner. The
Acquisition agreement requires the Company to submit the acquisition and the mandatory exchange of
the preferred stock to common stock to the stockholders for approval. The AMEX has authorized the
use of a written consent of a majority followed by an information statement in lieu of a proxy
statement for this purpose because of the vote to approve the acquisition and the share exchange is
assured. This process has been suspended temporarily due the SEC review of the Company’s December
31, 2004 financial statements. The Company is prepared to immediately comply with the regulatory
requirements, submit the information statement, exchange the shares and complete the terms of the
acquisition agreement.

     The Staff and the OCA requested the Company provide information as to it’s stock voting rights
before and after the acquisition. Exhibit “1” attached hereto is a summary listing of stock
ownership by groups immediately before October 12, 2004, and after October 12, 2004. The Exhibit
is consistent with and based in part upon information contained in Amendment No. 6 to Schedule 13D
for event of October 12, 2004 (the “Amended Schedule 13D”) filed on behalf of Basic Capital
Management, Inc., (“BCM”), International Health Products, Inc., (“IHPI”), TacCo Financial, Inc.,
(“TFI”), JRG Investment Co., Inc., (“JRGIC”), and Gene E. Phillips, an individual (“Phillips”).
For purposes of such Amended Schedule 13D, all of BCM, IHPI, TFI, JRGIC and Phillips are
collectively referred to as the “Reporting Persons” who may deemed to constitute a “Person” within
the meaning of Section 13d of the Securities Exchange Act of 1934, as amended. The reasons for the
collective determination are set forth in such Amended Schedule 13D to which reference is hereby
made. That collective “group” including TFI, JRGIC and IHPI, owned a total of 195,452 shares (or
20%) at October 12, 2004.

     In addition, another entity, Gainesville Real Estate LLC (“Gainesville”), owned 200,130
shares (approximately 20.48%) of Common Stock of GBR (which had been held since December 31, 2003)
at October 12, 2004. Gainesville was at that time controlled by Richard D. Morgan and indebted to
TFI. Morgan also held a Warrant to purchase 170,000 shares of GBR Common Stock at an exercise
price of $3.58 per share, the market price of GBR Common Stock on October 12, 2004. On December
14, 2004, Gainesville transferred 200,130 shares of GBR to TFI in payment of certain indebtedness.
On the same date, Morgan transferred the Warrant to purchase 170,000 shares of GBR
Common Stock

Office of the Chief Accountant

United States Securities and Exchange Commission

August 29, 2005

Page 4

to TFI and transferred to TFI all Morgan’s rights under a Stock Option Agreement dated
December 16, 2003 covering 40,000 shares of GBR Common Stock at an exercise price of $2.60 per
share.

     Subpart (b) of paragraph 17 of SFAS 141 states:

     ”(b). The existence of a large minority voting interest in the combined entity
when no other owner or organized group of owners has a significant voting interest —
all else being equal, the acquiring entity is the combining entity whose single
owner or organized group of owners holds the large minority voting interest in the
combined entity.”

Factual Analysis of subpart (b).

     On October 12, 2004, three entities (TFI, JRGIC and IHPI) identified with one of the Sellers
owned and controlled a total of 195,452 shares (or approximately 20%) out of the then total
outstanding shares of 977,004 shares of GBR Common Stock. Another entity, Gainesville, owned
200,130 shares (approximately 20.49%), which shares were subsequently transferred to TFI. On
October 12, 2004, the Sellers (Gene Phillips, his son Brad Phillips, and the brothers, Ron and Jeff
Finley) received a total of 31,500 shares of Series J 2% Preferred Stock of GBR, as interim
consideration for their CableTEL AD common stock, each share of which carries five votes voting on
all issues with the Common Stock together as a single class. On that basis, the Sellers held
157,500 votes out of a total of 1,134,503 then votes possible (977,004 Common Stock votes and
157,500 Preferred Stock votes). After the conclusion of the acquisition, the Sellers holding the
Series J 2% Preferred Stock, together with four entities identified with Phillips, controlled at
least a total of 553,080 votes out of total votes of 1,134,503 (approximately 48.8%), which
established after October 12, 2004 a large minority voting interest in the combined entity.

     This represents the largest organized minority voting interest. The value of Mr. Phillips
direct investment in CableTEL AD (approximately $16,000,000), his direct ownership of CableTEL and
his direct involvement in CableTEL AD (Board of Directors) strongly suggests Mr. Phillips voting
interests will favor ratification of the acquisition agreement and mandatory exchange of shares.

     Subpart (c) of paragraph 17 SFAS 141 states:

     ”(c). The composition of the governing body of the combined entity — all else
being equal, the acquiring entity is the combining entity whose owners or governing
body has the ability to elect or appoint a voting majority of the governing body of
the combined entity.”

Office of the Chief Accountant

United States Securities and Exchange Commission

August 29, 2005

Page 5

Factual Analysis of subpart (c).

     Prior to October 12, 2004, the Board of Directors of GBR consisted of five individuals, two of
whom (Gene S. Bertcher and Victor L. Lund) had served for several years on the Board of Directors.
The other three directors (Roz Campisi Beadle, James E. Huffstickler and Dan Locklear) were elected
in December 2003 in connection with a determined policy to have a majority of the directors be
independent. Prior to and as of October 12, 2004, before giving effect to the Acquisition
Agreement, Messrs. Lund and Bertcher each held shares of GBR Common Stock constituting
approximately 11.16% and 7.35%, respectively, and the group of entities deemed to be a “group” with
Phillips held

     approximately 20%, while Gainesville held an additional 20%. Directors are elected by plurality of
votes cast at a meeting of stockholders held for that purpose.

     After giving effect to the transaction on October 12, 2004, as noted in subpart (a) above,
holders of the Series J 2% Preferred Stock (including Phillips) together with the group of entities
filing the Amended Schedule 13D, and the shares ultimately acquired by TFI constituted at least
48.8% of the outstanding votes, which would provide to that group the ability to elect or appoint
more than a voting majority of the governing body of the combined entity, and in fact, all of the
members of the Board of Directors of the combined entity. To that end, shortly after the Annual
Meeting of Stockholders of GBR held in late

     October 2004, one of the Sellers, Ron Finley, was elected as a member of the Board of Directors and
Chairman of the Board of Directors, as well as Chief Executive Officer of GBR as noted under
subpart (d) below. It should be noted that Messrs. Lund and Bertcher have already voted in favor
of the acquisition and the mandatory share exchange.

     Subpart (d) of paragraph 17 SFAS 141 states:

     ”(d). The composition of the senior management of the combined entity — all
else being equal, the acquiring entity is the combining entity whose senior
management dominates that of the combined entity. Senior management generally
consists of the chairman of the board, chief executive officer, chief operating
officer, chief financial officer, and those divisional heads reporting directly to
them, or the executive committee if one exists.”

     Factual Analysis of subpart (d).

     Prior to October 12, 2004 and the Acquisition Agreement, GBR’s senior management
consisted of Gene S. Bertcher as President, Chief Executive Officer and Chief Financial Officer.
After the Acquisition Agreement, Gene S. Bertcher remained as President and Chief Financial Officer
of GBR, but Ron Finley (one of the Sellers) was elected as the Chief Executive Officer and Chairman
of the Board of GBR. In addition, Ron Finley and Gene Phillips continue to serve on the Board of
Directors of CableTEL AD, the Company’s

Office of the Chief Accountant

United States Securities and Exchange Commission

August 29, 2005

Page 6

dominate operating division representing over
90% of the Company’s post acquisition activities. Ron Finley also continues in his capacity
as Chairman of the Board, Chief Executive Officer and President of CableTEL AD. The Acquisition
Agreement resulted in no change in management of CableTEL AD, either at the level of the Board of
Directors or operational management. The same individuals serve in the same capacities both before
and after October 12, 2004, as dictated by the Sellers, to ensure a continuity of those operations
until and at least through the exchange of Preferred Stock for Common Stock.

     Subpart (e) of paragraph 17 SFAS 141 states:

     ”(e). The terms of the exchange of equity securities — all else being equal,
the acquiring entity is the combining entity that pays a premium over the market
value of the equity securities of the other combining entity or
entities.9”