SecProbe.io

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      December 29, 2005

Via U.S. Mail and Facsimile

Jorma Ollila
Chief Executive Officer
Nokia Corporation
Keilalahdentie 4
P.O. Box 226
FIN-00045
Espoo, Finland

RE:		Nokia Corporation
		Form 20-F for the fiscal year ended December 31, 2004
		File No. 1-13202

Dear Mr. Ollila:

      We have limited our review of your Form 20-F for the fiscal
year ended December 31, 2004, to disclosures relating to your
contacts with countries that have been identified as state
sponsors
of terrorism, and will make no further review of those forms.  Our
review with respect to this issue does not preclude further review
by
the Assistant Director group with respect to other issues.  At
this
juncture, we are asking you to provide us with supplemental
information, so that we may better understand your disclosure.
Please be as detailed as necessary in your response. After
reviewing
this information, we may 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
filings.
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.

General -

We note that on page 33 of your 20-F you state that during 2004
you
gained new network infrastructure customers in Libya.  We also
note
that on your website you indicate contacts with Iran, Syria and
Libya.  In light of the fact that Iran, Syria and Libya have been
identified by the U.S. State Department as state sponsors of
terrorism; Iran and Syria are subject to economic sanctions
administered by the U.S. Treasury Department`s Office of Foreign
Assets Control; and Libya was subject to similar sanctions until
September 21, 2004, please describe for us the extent and nature
of
your past, current, and anticipated contacts with Iran and Syria,
and
your past contacts with Libya.  Advise us whether any products or
services provided have military application.  Address for us the
materiality to you of your contacts with Iran, Syria and Libya,
and
whether those contacts constitute, individually or in the
aggregate,
a material investment risk for your security holders.

In preparing your response please consider that evaluations of
materiality should not be based solely on quantitative factors,
but
should include consideration of all factors that a reasonable
investor would deem important in making an investment decision,
including the potential impact of corporate activities upon a
company`s reputation and share value.  In this regard, we note
that
Arizona and Louisiana have adopted legislation requiring their
state
retirement systems to prepare reports regarding state pension fund
assets invested in, and/or permitting divestment of state pension
fund assets from, companies that do business with countries
designated as state sponsors of terrorism.  Your materiality
analysis
should address the potential impact of the investor sentiment
evidenced by these actions.

Closing Comments

      Please respond to this comment within 10 business days or
tell
us when you will provide us with a response.  Please file your
response letter on EDGAR.

      We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings to be certain that the
filings include all information required under the 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 the
company`s
disclosure, they are responsible for the accuracy and adequacy of
the
disclosures they have made.

      In connection with responding to our comment, 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.

      Please understand that we may have additional comments after
we
review your response to our comment.  Please contact Jack
Guggenheim
at (202) 551-3523 if you have any questions about the comment or
our
review.  You may also contact me at (202) 551-3470.

								Sincerely,

								Cecilia D. Blye, Chief
								Office of Global Security
Risk

cc: 	Larry Spirgel
		Kyle Moffatt
		Division of Corporation Finance
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Jorma Ollila
Nokia Corporation
December 29, 2005
Page 1

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-5546

         DIVISION OF
CORPORATION FINANCE

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