SecProbe.io

<DOCUMENT>
<TYPE>LETTER
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>
Mail Stop 0407

      							July 11, 2005

Alexander Anthony Arena
Group Chief Financial Officer
PCCW Limited
39th Floor, PCCW Tower
TaiKoo Place
979 King`s Road
Quarry Bay, Hong Kong

	Re:	PCCW Limited
      Form 20-F for the fiscal year ended December 31, 2004
		Filed May 12, 2005

Dear Mr. Arena:

      We have reviewed your filing and have the following
comments.
We have limited our review of your filing to those issues we have
addressed in our comments.  Where indicated, we think you should
revise your documents in response to these comments.  If you
disagree, we will consider your explanation as to why our comment
is
inapplicable or a revision is unnecessary.  Please be as detailed
as
necessary in your explanation.  In some of our comments, we may
ask
you to provide us with information so we may better understand
your
disclosure.  After reviewing this information, we may or may not
raise additional comments.

	Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.

Form 20-F for the Fiscal Year ended December 31, 2004

Capacity Prepayment Agreement, page 51
1. Please tell us how you accounted for the write-off of the
capacity
prepayment under US GAAP and the basis for the accounting.  It is
unclear to us why you are writing off the pre-purchased capacity
when
Reach is still providing you with the capacity under the
connectivity
agreements.

Item 5. Operating and Financial Review and Prospects, page 53
2. We note your presentation of Adjusted EBITDA and Adjusted
EBITDA
margin.  Please expand your future filings to disclose the
substantive reasons why you believe the presentation of these
measures provide useful information to investors regarding your
operating performance and liquidity.  You must also clearly
explain
how your measure of Adjusted EBITDA differs from EBITDA and
reconcile
these measures to the most directly comparable GAAP measures, net
income (loss) and cash flows from operating activities. Please
address this comment throughout your filing.

Consolidated Income Statements, page F-3
3. See your line item, "Operating profit before net gains on
investments, provisions for impairment losses and restructuring
costs."  Please confirm to us that the presentation of this line
item
on the consolidated income statements is either required or
expressly
permitted by the standard-setter that establishes Hong Kong GAAP.
Please see question 28 of our frequently asked questions regarding
the use of Non-GAAP financial measures available on our website at
http://www.sec.gov/divisions/corpfin/faqs/nongaapfaq.htm.

*    *    *    *

      As appropriate, please amend your Form 20-F and respond to
these comments within 10 business days or tell us when you will
provide us with a response.  You may wish to provide us with
marked
copies of the amendment to expedite our review.  Please furnish a
cover letter with your amendment that keys your responses to our
comments and provides any requested information.  Detailed cover
letters greatly facilitate our review.  Please file your response
on
EDGAR.  Please understand that we may have additional comments
after
reviewing your amendment and responses to our comments.

	We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing to be certain that the
filing includes all information required under the Securities
Exchange Act of 1934 and that they have provided all information
investors require for an informed investment decision.  Since the
company and its management are in possession of all facts relating
to
a company`s disclosure, they are responsible for the accuracy and
adequacy of the disclosures they have made.

	In connection with responding to our comments, please
provide,
in writing, a statement from the company acknowledging that

* the company is responsible for the adequacy and accuracy of the
disclosure in the filings;

* staff comments or changes to disclosure in response to staff
comments do not foreclose the Commission from taking any action
with
respect to the filings; and

* the company may not assert staff comments as a defense in any
proceeding initiated by the Commission or any person under the
federal securities laws of the United States.

      In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in our review of your filings or
in
response to our comments on your filings.

      You may contact Michael Henderson, Staff Accountant, at
(202)
551-3364 or Dean Suehiro, Senior Staff Accountant, at (202) 551-
3384
if you have questions regarding comments on the financial
statements
and related matters.  Please contact me at (202) 551-3810 with any
other questions.

								Sincerely,

								Larry Spirgel
								Assistant Director
??

??

??

??

Alexander Anthony Arena
PCCW Limited
July 11, 2005
Page 3

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549

         DIVISION OF
CORPORATION FINANCE

</TEXT>
</DOCUMENT>