SecProbe.io

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

Securities and Exchange Commission
Mail Stop 3561
CF/AD11
100 F St. NE
Washington, DC 20549-3561

									August 23, 2005

Mr. Hasnul Suhaimi
President Director
PT Indosat Tbk
Indosat Building
Jalan Medan Merdeka Barat, 21
Jakarta 10110, Indonesia

	Re:	PT Indosat Tbk
      Form 20-F for Fiscal Year Ended December 31, 2004
      Filed June 29, 2005
		File No. 1-13330

Dear Mr. Suhaimi:

      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 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
Financial Statements, page F-1
Notes to Consolidated Financial Statements
44. Summary of Significant Differences Between Accounting
Principles
Followed By The Companies and U.S. Generally Accepted Accounting
Principles ("GAAP"), page F-119

1. We note in your reconciliation of net income according to the
consolidated financial statements prepared under Indonesian GAAP
and
net income in accordance with U.S. GAAP the 7,411,702 million Rp
adjustment for "Realized gain on difference in value from
restructuring transactions of entities under common control" and
the
related disclosure provided in footnote 44(k).  Explain to us why
it
is not necessary for you to provide a similar adjustment for this
difference in GAAP in your reconciliations of stockholders` equity
or
revise to do so.

2. We are unable to reconcile the amount of stockholders` equity
in
accordance with U.S. GAAP as of December 31, 2003 to the amount of
stockholders` equity in accordance with U.S. GAAP as of December
31,
2004 after considering the impact of net income in accordance with
U.S. GAAP for the year ended December 31, 2004, 2004 dividends and
equity transactions.  So that we may clearly understand the items
that impacted stockholder`s equity in accordance with U.S. GAAP,
please provide us a roll forward of your US GAAP stockholder`s
equity
from December 31, 2002 through December 31, 2004.  Separately
identify and explain all items that impacted stockholders` equity
in
accordance with U.S. GAAP during this two-year period.

*    *    *    *

      Please respond to these comments within 10 business days or
tell us when you will provide us with a response.  Please furnish
a
letter that keys your responses to our comments and provides any
requested information.  Detailed letters greatly facilitate our
review.  Please understand that we may have additional comments
after
reviewing your 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 Joseph M. Kempf, Senior Staff Accountant, at
(202) 551-3352 or Robert S. Littlepage, Accountant Branch Chief,
at
(202) 551-3361 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

??

??

??

??

Mr. Hasnul Suhaimi
President Director
PT Indosat Tbk
August 23, 2005
Page 3

</TEXT>
</DOCUMENT>