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September 29, 2023

 VIA EDGAR

Securities and Exchange Commission

Division of Corporation Finance

Office of Technology

100 F. Street, N.E.

Washington, D.C. 20549

Attention: Inessa Kessman

    Robert Littlepage

    Re: Telecom Argentina SA

    Form 20-F for the Fiscal Year Ended December 31, 2022

    File No. 001-13464

Dear Ms. Kessman and Mr. Littlepage,

By letter dated August 31,
2023, you provided certain comments on the annual report on Form 20-F of Telecom Argentina S.A. (the “Company,” “Telecom”
or “we”) for the year ended December 31, 2022 (the “2022 Form 20-F”). This letter sets forth our
responses to these comments. For your convenience, we have reproduced the comments below in italics and have provided responses immediately
below each comment.

Comment 1: Operating and Financial Review and Prospects (A.1)
2022 Compared to 2021, page 75

1. On page 75 you disclose and
discuss Adjusted EBTIDA before the comparable IFRS measure. In future filings please disclose and discuss the comparable IFRS measure,
net income (loss), with equal or greater prominence. Refer to Item 10(e)(1)(i)(A) of Regulation S-K and Question 102.10 of the Compliance
and Disclosure Interpretations for Non-GAAP Financial Measures. Please apply this comment to all future filings where a Non-IFRS measure
is presented, including Form 6-K's showing earnings results for your quarters.

Response:

The Company acknowledges
the Staff’s comment, and in response, the Company respectfully advises the Staff that it proposes to make the requested changes
in future filings on Form 20-F and current reports on Form 6-Ks. To illustrate, please refer to the table and paragraphs below:

    Year ended
 December 31,

    2022
    2021
    Total Change

    (P$ million)
    %
    (P$ million)

    Revenues
      729,182
      828,831
      (12.0 )
      (99,649 )

    Operating costs (without depreciation, amortization and impairment of fixed assets)
      (528,802 )
      (570,210 )
      (7.3 )
      41,408

    Adjusted EBITDA(1)
     200,380
     258,621
     (22.5 )
     (58,241 )

    Depreciation, amortization and impairment of fixed assets
      (495,321 )
      (264,050 )
      87.6
      (231,271 )

    Operating loss
      (294,941 )
      (5,429 )
      N/A
      (289,512 )

    Earnings from associates
      819
      770
      6.4
      49

    Debt financial expenses
      29,744
      55,906
      (46.8 )
      (26,162 )

    Other financial results, net
      32,234
      33,015
      (2.4 )
      (781 )

    Income tax benefit (expense)
      26,504
      (64,900 )
      N/A
      91,404

    Net (loss) income
      (205,640 )
      19,362
      N/A
      (225,002 )

    Net (loss) income attributable to:

    Telecom Argentina (Controlling Company)
      (207,833 )
      16,878
      N/A
      (224,711 )

    Non-controlling interest
      2,193
      2,484
      (11.7 )
      (291 )

    Adjusted EBITDA(1)
      200,380
      258,621
      (22.5 )
      (58,241 )

 (1) Adjusted EBITDA is a non-GAAP measure. See the purpose of use of adjusted
EBITDA and reconciliation of, defined as our net (loss)/
income to adjusted EBITDA in section “less
income taxes, financial results, earnings (losses) from associates, depreciation, amortization and impairment of fixed assets. For further
information on the use of adjusted EBITDA, see “Item 5— Operating and Financial Review and Prospects—Adjusted
EBITDA.”.

In
2022, Adjusted EBITDA totaled P$200,380 million, representing 27.5% of consolidated revenues.
Depreciation and amortization totaled P$495,321 million (which includes the effect of goodwill impairment for P$243,900 million). Consequently,
the operating loss for 2022 amounted to P$294,941net
loss amounted to P$205,640 million, representing (28.2%) of consolidated revenues. The decrease in 2022 compared to 2021 was mainly due
to a decrease in consolidated revenues of P$99,649 million, an increase in impairment of fixed assets of P$243,634 million, and a decrease
in financial results, net of P$26,943 million, which were partially offset by a decrease in operating cost (without depreciation, amortization
and impairment of fixed assets) of P$41,408 million, as well as a decrease in income tax expense of P$91,404 million.

In 2022, net
loss amounted to P$205,640 million. Additionally, financial results, net amounted to P$61,978 million and income tax benefit amounted
to P$26,504Adjusted EBITDA totaled P$200,380 million, representing
27.5% of consolidated revenues. The decrease in 2022 compared to 2021 was mainly due to a decrease in consolidated revenues of P$99,649
million, partially offset by the decrease in operating cost (without depreciation, amortization and impairment of fixed assets) of P$41,408
million.

Comment 2: Operating and Financial Review and Prospects (A.1)
2022 Compared to 2021

2. On pages 76 to 79 you attribute
fluctuations in revenue to decreases in ARPU and changes in the number of customers. In future filings please also discuss the underlying
reason for the decrease or increase in ARPU and the number of customers. We refer to guidance in Item 5 of Form 20-F. Provide us with
your proposed future disclosure.

Response:

The Company acknowledges
the Staff’s comment, and in response, it respectfully advises the Staff that, in future filings on Form 20-F, the Company will disclose
in greater detail the increases or decreases of ARPU and number of customers that affect the Company’s revenues. Below is an illustration
of the disclosures that the Company will include in our future filings on Form 20-F (pages 76-79 of the 2022 Form 20-F):

Mobile Services

Mobile services revenues
in 2022 amounted to P$293,112 million (a decrease of P$20,760 million or 6.6% as compared to 2021), being the principal contributor to
our total services revenues for 2022 (43.1% of consolidated services revenues in 2022 as compared to 40.7% in 2021).

The effect generated by
the restatement in current currency as of December 31, 2022 included in Mobile services revenues amounted to P$75,949 million and P$178,426
million in 2022 and 2021, respectively.

Mobile services revenues
in Argentina amounted to P$268,035 million (a decrease of P$13,291 million as compared to 2021), due
to a decrease of. Mobile internet services revenues represented
86% and 75% of the mobile services revenues as of December 31, 2022 and 2021, respectively. This decrease was mainly due to 8.3%
decrease in the ARPU, partially offset by an
increase ofa 0.6% increase
in the number of customers.

Personal’s
mobile customers amount to 20.2 million and 20.1 million as of December 31, 2022 and 2021, respectively. The main ratios related to the
services provided to these customers were:

·
57% of total are prepaid customers and 43% consist of postpaid customers as of December 31, 2022, compared to
59% and 41% respectively, as of December 31, 2021.

·
Mobile internet services revenues represent 86% of Personal’s customer total services revenues as December
31, 2022, compared to 75% as of December 31, 2021.

ThePersonal’s
ARPU amounted to P$1,102.6 as of December 31, 2022 (vs.compared
to P$1,201.9 as of December 31, 2021), representing an 8.7% decrease. The.
This decrease was mainly explained by the fact that, as a consequence of the 94.8% inflation in Argentina, the Company (and other competitors
in the ICT industry) was unable to increase its prices during 2022 to the same extent as the increase in inflation (the effect
generated by the restatement in current currency as of December 31, 2022 included in ARPU amounted to P$282.5 and P$681.3 as of December
31, 2022 and 2021, respectively.).
Such decrease was partially offset by an increase in the migration of customers from prepaid to postpaid services (which have a higher
ARPU than prepaid customers). Additionally, the decrease in ARPU is also explained by the fact that we granted greater discounts to customers
in order to maintain the customer base, considering the intense competition in the market.

·
The average churn rate per month amounted to 2.3% in December 2022 (vs. 1.5% average in December 2021).

Regarding
infrastructure, the Company continued to enhance the mobile Internet experience of its customers through the deployment of its 4G and
4G+ network throughout the country, reaching more than 14.8 million customers with 4G devices. The traffic carried by 4G technologies
during 2022 corresponds to 95% of the total traffic. Telecom continued with the expansion of 5G to support the growth of the mobile Internet
and the improvement in the quality of service along with the launch of new Value Added Services.

Personal’s
mobile customers amounted to 20.2 million and 20.1 million as of December 31, 2022 and 2021, respectively. Out of the total mobile customers
as of December 31, 2022, 57% were prepaid customers and 43% were postpaid customers, whereas as of December 31, 2021, 59% were prepaid
customers and 41% were postpaid customers. The increase in 2022 was mainly explained by our commercial efforts to maintain and attract
new customers to our services in a scenario of intense competition between the different market participants. Additionally, the average
churn rate per month amounted to 2.3% in December 2022 (compared to a 1.5% average in December 2021).

Telecom
has been preparing to receive 5G technology by expanding the coverage, availability and capacity of the network through a technological
reconversion and continuing the deployment of 4G. In 2022, 143 sites with 5G DSS mobile antennas were enabled in Buenos Aires, Rosario,
the Atlantic Coast, Córdoba, Santa Fe, Corrientes, Posadas and Paraná.

ARPU of Mobile Services
in Argentina

A monthly operational measure
used in the mobile services is ARPU, which we calculate by dividing adjusted total service revenues —excluding out collect wholesale
roaming, cell site rental and reconnection fee revenues and others— (divided by 12 months) by the average number of subscribers
during the period. ARPU is not a measure calculated in accordance with IFRS and our measure of ARPU may not be calculated in the same
manner as similarly titled measures used by other companies. In particular, certain components of service revenues are excluded from Personal’s
ARPU calculations presented in this Annual Report. Management believes that this measure is helpful in assessing the development of the
subscriber base of mobile services. The following table shows the reconciliation of total service revenues to such revenues included in
the ARPU calculations of 2022:

    Year ended

 December 31,
 2022

    (P$ million)

    Total Mobile service revenues

    268,035

    Components of service revenues not included in the ARPU calculation: Outcollect wholesale roaming, cell sites rental, Reconnection fees and others

    (2,144
    )

    Adjusted total service revenues included in the ARPU calculation

    265,891

    Average number of subscribers during the year (thousands)

    20,097

Mobile services revenues
generated in Paraguay amounted to P$25,077 million in 2022 (vs. P$32,546 million in 2021, representing a 22.9% decrease). The decrease
was mainly due to thea 28%
decrease in Núcleo’s ARPU and
the customer base, partially offset by the appreciation of the Guaraní against the Argentine Peso. The
main ratios related to mobile services in Paraguay as of December 31, 2022 were:

Núcleo’s
ARPU amounted to P$893.3 as of December 31, 2022 (vs. P$1,239.9 as of December 31, 2021), representing a 28% decrease. The decrease in
ARPU was mainly due to the fact that we granted greater discounts to customers in order to maintain the customer base, considering the
intense competition and the widespread use of fixed internet, which was partially offset by an increase in the migration of customers
from prepaid to postpaid services (which have a higher ARPU than prepaid customers).

·
Núcleo’s subscribercustomer
base remachined
stable amounting to 2.3 million customers as of December 31, 2022;

·
. Out approximately
79% of the total ofmobile
customers consisted of prepaid customers, and 21% consist of postpaid customers, as of
December 31, 2022; while approximately 82% of the total of customers consisted of,
79% were prepaid customers,  and 18% consisted
of21% were postpaid customers, whereas
as of December 31, 2021;

,
82% were prepaid customers, and 18% were postpaid customers. Additionally, ARPU amounted to P$893.3
as of December 31, 2022 (vs. P$1,239.9 as of December 31, 2021), representing a 28%; and

the average
churn rate per month amounted to 3.3% in 2022 and 2021.

Internet Services

Internet services revenues
amounted to P$161,740 million in 2022 (equivalent to 23.8% of total consolidated services revenues), decreasing P$15,070 million or 8.5%
as compared to P$176,810 million in 2021, mainly due to the decrease in the Broadband Internet access
ARPU of 9.3%, which reached P$3,052.4 in 2022 as compared to P$3,364.3 in 2021. The effect generated by the restatement
in current currency as of December 31, 2022 included in ARPUinternet
services revenues amounted to P$798.342,687
million and P$1,912 as of December 31,100,462
million in 2022 and 2021, respectively.

The
decrease in internet services revenues in 2022 was mainly due to the decrease in the Broadband Internet access ARPU of 9.3% and in the
customer base of 3.1%.

The
ARPU reached P$3,052.4 in 2022 as compared to P$3,364.3 in 2021. This decrease in ARPU is mainly explained by the fact that, as a consequence
of the 94.8% inflation in Argentina, the Company (and other competitors in the ICT industry) was unable to increase its prices during
2022 to the same extent as the increase in inflation (the effect generated by the restatement in current currency as of December 31, 2022
included in ARPU amounted to P$798.3 and P$1,912 as of December 31, 2022 and 2021, respectively). The decrease is also explained by the
discounts granted by the Company to maintain its customer base due to the intense competition in the market.

The customer base in 2022
amounted to 4.1 million subscribers, remaining approximately at the same level as 2021. Internet servicescompared
to 4.2 million in 2021. The decrease in the customer base was mainly due to the intense competition between the different market participants.
The decrease is further explained by a decrease in accesses in our xDSL (total digital subscriber
line) network, which have overall lower average connection speeds than our HFC and FTTH network accesses, where we have observed growth.
Additionally, the churn rate per month amounted to 1.6% and 1.5% as of December 31,in
2022 and 2021, respectively.

In connection with initiatives
to continue developing the experience of fixed internet service customers, duringtowards
the end of 2022, Personal announced that it doubled
the internet speed to all of its residential customers (with HFC,
FTTH technology), going from 50 Mb to 100 Mb, from 100 Mb to 300 Mb and from 300 Mb to 500 Mb, and the
lowest speeds went to 50 Mb. This process was carried out free of charge, without any additional management by customers.
More than three million customers received an increase in the speed of their contracted service without modifying their commercial conditions.

As
a consequence, customers Customers with a
service of 100 Mb or higher represented 79% and 32% of the total customer base as of December
31, 2022 and 2021, respectively. Within this range there are customers who have plans of 100 Mb or higher, that as of
December 31, 2022 amounted to 3.3 million, an increase of 140.9% as a whole compared to 2021.

As
The effect generated by the restatement in current currencyof
December 31, 2022, these customers represented 79% of our total customer base, whereas as of December 31, 2022
included in internet services revenues amounted to P$42,687 million and P$100,462 million in 2022 and 2021, respectively2021
they represented 32%.

ARPU of I