SecProbe.io

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Mail Stop 3561

      							July 12, 2005

Via U.S. Mail and Fax (30-210-61-08-819)

Mr. Dimitris Kouvatsos
Chief Financial Officer
TIM Hellas Telecommunications S.A.
66 Kifissias Avenue
15125 Maroussi
Athens, Greece

	Re:	TIM Hellas Telecommunications S.A.
      Form 20-F for the Year Ended December 31, 2004
		File No. 000-29726

Dear Mr. Dimitris:

      We have reviewed your filing and have the following
comments.
We have limited our review to only your financial statements and
related disclosures and do not intend to expand our review to
other
portions of your document.  If you disagree, we will consider your
explanation as to why our comment is inapplicable or a future
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 for the Year Ended December 31, 2004
Financial Statements and Notes
Recognition of Revenues, page F-14

1. We note that you have bundled arrangements and pre-paid
packages
to provide your products and services.  Tell us the nature of
various
products and services within the arrangements and packages, and
advise us how you allocate your revenues among these deliverables
under the guidance of EITF 00-21.
2. We note in your policy disclosure that "[r]evenues from the
sale
of handsets and accessories, net of discounts allowed, are
recognized
upon shipment to dealers or at point of sale (in the case of sales
the Company`s retail outlets), while revenues from the sale of
pre-
paid airtime cards and the pre-paid airtime ... are recognized
based
on usage."  Please expand your revenue recognition policy
disclosure
to explain your revenue earning processes for each of your
products
and services including, but not limited to, handsets and
accessories,
set up, monthly services and other value added services, and
advise
us.  As part of your response, please also explain to us how your
revenue recognition policies comply with the guidance in SAB 104.

*    *    *    *

      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 Andrew Mew, Staff Accountant, at (202) 551-
3377
or Robert S. Littlepage, Jr., Accounting 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

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Mr. Dimitris Kouvatsos
TIM Hellas Telecommunications S.A.
July 12, 2005
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