SecProbe.io

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Mail Stop 3561

      							August 22, 2005

Mr. Ekrem Tokay
Chief Financial Officer
Turkcell Iletisim Hizmetleri A.S.
Turkcell Plaza
Mesrutiyet Caddesi No: 153
34430 Tepebasi
Istanbul, Turkey

	Re:	Turkcell Iletisim Hizmetleri A.S.
      Form 20-F for Fiscal Year Ended December 31, 2004
		Filed June 30, 2005
		File No. 1-15092

Dear Mr. Tokay:

      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 documents.  Please address the following comments
in
future filings.  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 on 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 Fiscal Year Ended December 31, 2004

1. We note your participation in Irancell, a consortium of
telecommunications companies that has been awarded a GSM license
by
the Iranian government to develop the country`s mobile
communications
network system.  We also note that, in addition to the Irancell
GSM
license agreement, the company has plans for expanding operations
in
Iran.  In view of the fact that Iran has been identified by the
U.S.
State Department as state sponsors of terrorism, and is subject to
economic sanctions administered by the U.S. Treasury Department`s
Office of Foreign Assets Control (OFAC), please advise us of the
materiality to the company of its proposed operations in Iran, and
give us your view as to whether those operations constitute a
material investment risk for your security holders.  In addition,
because there are several conflicting published reports concerning
the status of the consortium`s revised Irancell license agreement,
please advise us of the current status of the agreement and
confirm
whether you have ultimately accepted the revised terms of the
agreement.  In your response, please explain the material terms of
the revised agreement.  Please also give us an overview of your
proposed timeline for formally beginning operations in Iran.

In preparing your response, please consider that evaluations of
materiality should not be based solely on quantitative factors,
but
should include consideration of all factors, including the
potential
impact of corporate activities upon a company`s reputation and
share
value, that a reasonable investor would deem important in making
an
investment decision.

*    *    *    *

      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.  Detail 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 filings 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 Inessa Berenbaum, Staff Accountant, at (202)
551-3371, Franklin Green, Attorney, at (2020 551-3522 or Sharon
Virga, Senior Staff Accountant, at (202) 551-3385 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. Ekrem Tokay
Turkcell Iletisim Hizmetleri A.S.
August 22, 2005
Page 3

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549

         DIVISION OF
CORPORATION FINANCE

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