SecProbe.io

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September 8, 2005

VIA EDGAR

Mr. Larry Spirgel
Assistant Director
U. S. Securities and Exchange Commission Mail Stop 3561
Washington, D.C. 20549
United States of America

  Re:      Rostelecom OJSC (the "Company")
           Form 20-F for the fiscal year ended December 31, 2004 (the
           "Form 20-F") Filed June 29, 2005
           File No. 1-15094
           Response to comment letter dated July 28, 2005

Dear Mr. Spirgel:

This letter  responds to the  comments of the Staff of the U.S.  Securities  and
Exchange Commission (the "Commission") on the Form 20-F set forth in the Staff's
letter dated July 28, 2005. To facilitate  your review,  we have set forth below
each of your  comments  with our  corresponding  response and have  numbered the
items to correspond to your original letter.

Investment Policy Highlights, page 23

1.   We note that you have  planned to phase out your analog  trunk lines which,
     per your  disclosure on page 29,  consisted of 15,810  lines.  Tell us your
     consideration  of  paragraph 8 of FAS 144.  Also tell us why the  estimated
     lives of these lines were not revised under US GAAP.

Response

The phasing out of our analog trunk lines in order to provide digital service to
virtually  all of our  customers  is one of the  major  areas  of  focus  of our
investment program.  However,  within our telecommunication  network, our analog
lines continue to provide the following principal functions:

o    Provision  of  telecommunication  services  in  regions  where our  digital
     networks  either do not exist or are not  sufficient  to fully  satisfy our
     customers' needs;

<PAGE>

o    Serve as back-up capacity to provide a continuous and uninterrupted service
     to our customers; and

o    Provision of telecommunication services to specific users who are unable to
     operate with our digital network.

Based on the  foregoing  uses of the analog  lines,  we  consider  them to be an
inseparable  part of our network  and we believe  the lines will  continue to be
utilized in this capacity for the remainder of their useful lives.

We  considered  the  provisions of FAS 144 as it relates to our analog lines and
concluded  that  we  operate  in  a  single  segment,  being  the  provision  of
long-distance  telecommunication  services through  operating our main intercity
network and the  international  telecommunications  gateways.  Our revenues come
from   customers   or  other   operators   for   carrying   traffic  or  renting
telecommunication  channels. Signals received by our equipment are directed in a
way that provides  optimal  capacity and use of our network,  including both our
digital and analog  lines -  regardless  of whether a client uses our digital or
analog  network.  We cannot  specifically  match our  revenues  in any region or
within  any  group  of  clients  with  individual  telecommunications  lines  or
equipment.

As a result,  we consider our entire  nationwide  network to be the lowest level
for which  identifiable cash flows are largely  independent of the cash flows of
other  assets  and  liabilities.  At  each  balance  sheet  date we  perform  an
assessment as to whether there is an indication that it may be impaired and give
consideration  to the  provisions of FAS 144. We believe that as of December 31,
2002,  2003 and 2004  there was no such  indication.  As such,  we  continue  to
believe  the  carrying  amount of our  analog  lines to be  recoverable  and the
remaining useful life to be appropriate.

Restatement of Historical Financial Statements, page 56

2.   We note that you  recognize  revenue "when it is probable that the economic
     benefits  associated with the  transaction  will flow to the enterprise and
     the amount of the revenue can be reliably  measured."  We further note your
     disclosure here that prior to the restatement, you "recognized revenues and
     expenses related to intercity and international telephone services based on
     the difference between actual billings and actual traffic.  This adjustment
     resulted in a build-up of an unbilled  receivable . . . , the realizability
     of which  could not be assured . . . . in the  absence of clear  regulatory
     and  contractual  guidelines."  Tell us why your  accounting is appropriate
     under US GAAP and include in your response  references  to the  appropriate
     accounting literature. Also tell us how you determined the actual billings.
     In this connection,

     o    in light of your decision to record revenues based on actual billings,
          tell us how you  concluded  that you have  recorded,  in revenue,  all
          amounts that are  realized or  realizable  and earned.  Refer to Topic
          13.A.1 of SAB 104.

<PAGE>

     o    Describe  the  unclear  regulatory  and  contractual  guidelines  that
          preclude recognition of actual traffic into revenues.

     o    Tell us how you intend to account for any unrecorded  unbilled traffic
          as of the 2004  balance  sheet date and if any amount is  subsequently
          realizable or measurable, pending further resolution.

     o    Additionally,  tell us how you accounted for unbilled (but potentially
          billable)  traffic  occurring  between the billing cutoff date and the
          balance sheet date as well as the related costs.

     o    Tell us if you expect to revise your basis for revenue  measurement as
          a result of the implementation of the Unified Billing System (UBS). We
          note your  disclosure  on page 23 that the new system is  expected  to
          improve the precision of  settlements  between  operators and automate
          the traffic routing process.

Response

Under  the  rules  governing  the  Russian   telecommunications   industry,  the
Inter-Regional  Telecommunications  Companies  originating traffic  (hereinafter
referred to as `IRCs') bill individual subscribers. We bill originating IRCs for
the  use  of  our  domestic   long-distance   network  and/or  for  the  use  of
international  networks.  Terminating  IRCs  bill us for  the  use of the  IRCs'
regional networks.  According to a government decree and corresponding bilateral
contracts  between us and the  individual  IRCs, we bill  originating  IRCs on a
monthly basis, based on current rates and the prior month's actual traffic.

Thus,  the bill for a given month does not take into account the actual  traffic
for that month.  For example,  we would bill an originating IRC for the month of
May based on the actual  traffic in April charged at the billing rates in effect
at the time of billing.

As a result of these  billing and  contractual  arrangements,  for our  services
rendered from January through  December 2004, we are  contractually  entitled to
bill and collect for the amount of actual  traffic we carried from December 2003
through November 2004.

Prior to the restatement,  we accrued for the difference  between actual traffic
and billings  made for the  services  provided in December to record our revenue
for any given year based on January through  December actual traffic (i.e.,  the
"true-up amount").  As a result, prior to the restatement our December 31, 2003,
accounts  receivable  balance included January 2004 billings.  In 2004, based on
our  assessment  of  the  contractual  terms,  we  concluded  that  the  accrued
receivable  balance is not billable,  and therefore,  not collectible.  In other
words,  the accrued  receivable  balance  represented a "cut-off" error that had
built up over a number  of  years.  This  assessment  is based on the  following
considerations:

<PAGE>

1.   Based on our review of the  contractual  provisions and after  consultation
     with our legal  counsel,  we concluded  that there is no  legal/contractual
     basis for us to be able to claim the true-up amount from the IRCs.

2.   We and our  controlling  shareholder--which  is also the IRCs'  controlling
     shareholder  (Svyazinvest)--do  not  expect  that  there  will  be a  final
     settlement  of the  true-up  amount  should the current  payment  scheme be
     changed or  terminated  in the future.  If we had to terminate  the current
     contracts,  for example,  on December 31, 2004,  we would bill for December
     2004 traffic in the amount of November  2004 actual  traffic,  and we would
     not be able to bill and collect any difference between actual November 2004
     and December 2004 traffic, regardless of the volume of December 2004 actual
     traffic.

3.   We have never billed or requested  payment from the IRCs for any portion of
     the true-up amount and, therefore,  do not have a history of collections of
     such amounts.

4.   Our  reconciliation  of  receivable  balances with the IRCs at December 31,
     2004 did not include the true-up amount.

Therefore,  we have  concluded  that we should record  revenues based on current
contractual terms rather than actual traffic in view of the revenue  recognition
criteria  outlined  in  Topic  13 of SAB  104 as at  least  two of the  criteria
referred to below are not met:

1.   Persuasive  evidence of the arrangement  exists in the form of the relevant
     government decrees and orders,  bilateral contracts between us and the IRCs
     and existing  business  practices.  The  contractual  terms  stipulate that
     current  month  billings are  measured  based on the prior  month's  actual
     traffic  and do not  provide  for a true-up  based on the  current  month's
     actual traffic.

2.   Delivery has occurred or services  have been  rendered  since  services are
     delivered at the moment  long-distance calls are made, which is captured by
     our systems.

3.   The selling price is fixed and determinable, as it is based on actual usage
     priced at contractually determined tariffs.

4.   Collectibility is reasonably assured based on the history of collections of
     billed amounts from the respective IRCs.

Similar to  revenue  arrangements,  we are  billed for our costs  based on prior
month actual costs. If we had to terminate the current contract, for example, on
December 31, 2004,  we would be billed for our December 2004 costs in the amount
of our November 2004 actual  traffic.  We would not be liable for any difference
between  the  actual  November  2004  and  December  2004  costs.   Accordingly,
revenue-related costs were also restated to agree with contractual provisions.

In summary,  we concluded  that our prior  accounting for IRC revenues and costs
was not correct, and after consultations with Ernst&Young, we decided to restate
our previously issued financial statements.

<PAGE>

Finally,  we do not expect that the  implementation  of the new Unified  Billing
System will lead to changes in our revenue  recognition and measurement  because
the system, by itself, does not change the regulatory environment or contractual
terms.  However,  as we  described in Note 31(d) to our  Consolidated  Financial
Statements,  we expect that new Russian  regulations and contractual  terms will
probably lead to changes in our business practices  resulting in a new system of
accounting  for our revenues and  expenses.  The  principal  difference  is that
revenues  and related  costs would be  measured  based on actual  traffic of the
current month, rather than of the prior month.

Novation Agreements, page 102

3.   Tell  us the US GAAP  accounting  impact,  if any,  which  arose  from  the
     substitution of your lease  obligations  into borrowings under the Novation
     Agreements and the related transfer of assets.

Response

The  Novation  agreements  were  executed  in  conjunction  with the sale of our
consolidated  investment  in  RTC-Leasing  during 2003 in order to purchase  the
remaining interest in certain  telecommunications  equipment previously owned by
RTC-Leasing.

From the  standpoint of the Company's  consolidated  financial  statements,  the
execution  of the  Novation  agreements  did not result in any  separate US GAAP
accounting  impact. The Company's basis in the related assets was a component of
the overall RTC-Leasing  disposal transaction that resulted in the net loss from
discontinued operations disclosed in our Consolidated Statements of Income.

4.   Tell us the nature of the accounts  receivable written off in the amount of
     RUR 774 million.

Response

Prior to 2002,  some  revenues and related  receivables  were  recognized by our
Moscow branch.  However,  these  receivables  were not  collected.  Based on our
investigation  performed  in 2002,  we  concluded  that these  receivables  were
recorded  as a  result  of  unauthorized  access  to our  network  and  that the
receivables were probably not collectable. A provision for doubtful accounts was
recorded in 2002. Our policy is that when we detect such unauthorized  access we
initiate  certain  legal   procedures.   If,  upon  completion  of  these  legal
procedures,  we conclude that we will not be able to collect the receivable,  we
write-off  the  receivable.  The amount of RUR 774 million  written-off  in 2004
relates to such accounts receivable  (previously  reserved for during 2002) that
we concluded were not collectible after legal proceedings had been completed.

<PAGE>

Note 18. Interest-bearing loans, page F-34

5.   We note that the  Government,  which  has a  significant  ownership  in you
     through  Syzainvest,  forgave and wrote off fines and penalties  related to
     your overdue debt that resulted in a gain of RUR 752 million.  Tell us your
     consideration of SAB Topic 5.T.

Response

SAB Topic 5.T.  indicates that the Company may be required to account for such a
transaction   with  an   offsetting   contribution   to  capital,   "unless  the
stockholder's  action is  caused  by a  relationship  or  obligation  completely
unrelated to his position as a stockholder."

We  have  considered  this  literature  and  concluded  that  the   Government's
forgiveness of the penalties associated with the overdue debt should be recorded
as a gain rather than as a capital contribution because,  under these particular
circumstances,  the Government's action was completely unrelated to its position
as a stockholder,  but rather,  was taken for the health of overall  economy and
pursuant to specific  legislative  policy  designed to restore  stability to the
Russian economy. Our conclusion was based on the considerations set forth below.

In the early 1990s there was no developed  banking system in Russia.  Due to the
high  country  risks,  cross-border  financing  was not  available  for even the
largest  most-stable  Russian  companies  like  ours.  Therefore,   the  Russian
Government  acted as an  intermediary  and guarantor  between  foreign banks and
Russian  companies,  i.e.,  the Russian  Government  borrowed money from foreign
banks and provided loans to various Russian  companies for large  infrastructure
projects that contributed to the economic and social  development of Russia. The
loan  referred to in your  question  was granted to us (and was similar to loans
granted to many other Russian  companies in many  industries) in 1994 as part of
the above mentioned governmental program.

As a result of the severe  economic  and banking  crisis in 1998,  many  Russian
companies,  including  us,  defaulted  on such loans.  As part of its efforts to
facilitate  economic  growth in  Russia,  debt  forgiveness  was  offered by the
Government to all Russian companies (municipal, governmentally-owned or private)
with  similar  types of  borrowings  made  prior to  August  1,  1998.  The debt
forgiveness  program was enacted by Government Decree #435 of July 17, 2003, and
was  offered to all  entities.  The decree  indicated  that it was  intended  to
provide relief from certain