SecProbe.io

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             [China Eastern Airlines Corporation Limited Letterhead]

                                                                December 6, 2005

Via EDGAR and by Facsimile

Mr. David R. Humphrey
Branch Chief
Division of Corporation Finance
Securities and Exchange Commission
100 F Street, N.E.
Washington, DC 20549
United States of America

            Re:  Annual Report on Form 20-F for the Fiscal Year
                 ended December 31, 2004 (File No. 001-14550)
                 ----------------------------------------------

Dear Mr. Humphrey:

     China Eastern Airlines Corporation Limited (the "Company") has received the
comment letter from the staff of the Division of Corporation Finance, dated
August 1, 2005 (the "Comment Letter"), relating to the Company's Annual Report
on Form 20-F for the fiscal year ended December 31, 2004 (the "Form 20-F"),
which was filed with the Securities and Exchange Commission (the "Commission")
on June 24, 2005. On behalf of the Company, I wish to thank you and the other
members of the staff for taking the time to review the Form 20-F and for
providing us with your helpful comments.

     We understand that the Comment Letter was first sent to us by fax and mail
on August 1, 2005 and deeply regret the fact that we were not able to respond to
it timely. We received a copy of the Comment Letter for the first time on
December 3, 2005. I would like to take this opportunity to assure you that we
are reinforcing our internal procedures to ensure that all communications
(whether by mail, fax or telephone) from the Commission will be brought
immediately to the attention of Company officials responsible for Commission
filings. We will also review and revise our contact information included in our
Commission filings in order to avoid any future delays in receiving
communications from the Commission.
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Mr. David R. Humphrey                                                        -2-

     The Company notes that the staff has requested that the Company file its
response to the staff's comments within 10 business days from the date of the
Comment Letter. The Company has carefully reviewed and considered the staff's
comments, and is in the process of preparing a response to these comments.
Obviously, at this point we are already well past 10 business days from the
original August date of the Comment Letter. We will use every effort to respond
to the staff swiftly. However, with deep regrets, the Company believes that it
will not be in a position to respond to all of the staff's comments until
January 6, 2006 and would be grateful if the staff could accommodate the Company
in this regard.

     Thank you again for your time. Please feel free to contact Ms. Nian Zhou
(Legal Affairs, Office of the Secretary of the Board of Directors) at
86-21-5113-0922 with any questions you may have.

                                                        Very truly yours,

                                                        /S/ LUO Weide
                                                        ------------------------
                                                        LUO Weide
                                                        Chief Financial Officer

cc: Amy Geddes
    Margery Reich
    (Securities and Exchange Commission)

    Nian Zhou
    (China Eastern Airlines Corporation Limited)

    Amelia Yau
    Jack Li
    Frederick Mang
    Henry Chow
    (PricewaterhouseCoopers)

    Chun Wei
    Da-Wai Hu
    Peng Jiang
    Liu Fang
    (Sullivan & Cromwell LLP)

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