SecProbe.io

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Mail Stop 3561								August 9, 2005

Via U.S. Mail and Fax (852-21138118)

Raymond Wai Man Mak
Director - Finance

Sunday Communications Limited
13th Floor Warwick House
Taikoo Place 979 King`s Road
Quarry Bay
Special Administrative Region of Hong Kong
The People`s Republic of China

Re:	Sunday Communications Limited
	Form 20-F/A for the year ended December 31, 2004
      Filed July 6, 2005

	File No. 333-11470

Dear Mr. Wai Man Mak

      We have reviewed the above referenced filings and have the
following comments.  We have limited our review to only your
financial statements and related disclosures and will make no
further
review of your documents.  As such, all persons who are
responsible
for the adequacy and accuracy of the disclosure are urged to be
certain that they have included all information required pursuant
to
the Securities Exchange Act of 1934.  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 supplemental 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 the year ended December 31, 2004

Item 3.A Selected Financial Data, page 3

1. We refer to your disclosure of `net cash (outflow)/inflow` data
prepared in accordance with HK GAAP. Since these amounts could be
different under US GAAP, please revise your disclosure to include
amounts in accordance with US GAAP.

2. In addition, you should provide in a note to the financial
statements a quantified description of the material differences of
the cash flows reported between HK GAAP and US GAAP. Please refer
to
Form 20F Item 17 (c) (2) (iii).
3. Refer to your EBITDA presentation under US GAAP.  Since you
present a measure labeled as "EBITDA" as a measure of operating
performance, it is generally not appropriate to exclude "share of
losses from joint venture" since these charges are recurring.
Refer
to Item 10 of Regulation S-K and Question 8 of our Frequently
Asked
Questions document on non-GAAP measures which is available on our
website at:
<http://www.sec.gov/divisions/corpfin/faqs/nongaapfaq.htm>.  If
you
present a non-GAAP measure that excludes these recurring charges,
you
must provide detailed disclosures why management believes a
performance measure that excludes these recurring charges is
useful.
Your discussion should, at a minimum, disclose the following:
* the manner in which management uses the non-GAAP measure to
conduct
or evaluate the business;
* the economic substance behind management`s decision to use such
a
measure;
* the material limitations associated with the use of the non-GAAP
measure as compared to the use of the most directly comparable
GAAP
measure, net income (loss); and
* the manner in which management compensates for these limitations
when using the non-GAAP financial measure.

Revise your presentation as appropriate

4. Your definition of EBITDA does not conform to the commonly
understood definition of EBITDA.  Thus, it is not appropriate to
label it EBITDA.  Rather, you must call it something other than
EBITDA and use a name that clearly describes all adjustments.  You
must also clearly explain that your measure differs from EBITDA
and
that it is not comparable to EBITDA as reported by other companies
in
the industry.  Specifically, disclose the definition of the
acronym
EBITDA, earnings before interest, taxes, depreciation and
amortization, and explain that the calculation of your non-GAAP
measure also excludes "share of losses from joint venture."

Summary of differences between HK GAAP and US GAAP, page F-39

5. Expand your accounting policy for connection fees under US GAAP
to
disclose how you account for connection fees related to sales and
service agreements.  It appears that your policy for connection
fees
under US GAAP as is relates to the provision of mobile services
only.
Please clarify and disclose any difference in the accounting
policy
between sales through your direct sales channels and sales through
your dealers.

6. Tell us how you applied the consensus in EITF 00-21 and the
impact
in your financial statements.

7. Refer to your disclosure on sales of mobile phones and
accessories
at the bottom of page 35.  It is unclear to us how the rebate
program
works and the relationship with the prepaid services.  To help us
understand your accounting, please provide us with the related
journal entries.

8. Refer to the reconciling item to write back compensation cost
with
respect to the deferred compensation for share options. It is
unclear
to us why you wrote back the compensation cost.  Please explain.

Consolidated Statements of Profits and Losses, page F-42

9. It appears that the captions "cost of sales of mobile phones
and
accessories" and "cost of services" excludes depreciation and
amortization for property and equipment that directly attributed
to
the generation of revenue.  Revise to comply with SAB Topic 11: B
as
applicable, by identifying the amount of applicable depreciation
that
is excluded from the above captions. Alternatively, you can
indicate
that the above captions exclude `depreciation` and `amortization`.

10. In addition, you should revise to include the impairment loss
of
your investment in a joint venture within the caption `share of
losses of joint ventures`.

Other, page F-23

11. Refer to Note 12 and the investment in a joint venture.  It
appears that you were required to file separate financial
statements
of Atria under Rule 3-09 of Regulation S-X.  Please tell us how
you
determined that separate financial statements under Rule 3-09 of
Regulation S-X were not required.  When performing the income test
in
accordance with Rule 1-02(w) of Regulation S-X, you are required
to
include the impairment of your investment together with the equity
pick up in the income (loss) of the investee.  Supplementally
provide
us with your supporting calculations.

*    *    *    *

      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 supplemental information.  Please file your response
letter
on EDGAR.

	We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings reviewed by the staff to
be
certain that they have provided all information investors require
for
an informed 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 Al Rodriguez, Staff Accountant, at (202)
551-
3370 or Ivette Leon, Assistant Chief Accountant, at (202) 942-1982
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,
							/s/ Carlos Pacho
							for Larry Spirgel
							Assistant Director
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Raymond Wai Man Mak
Sunday Communications Limited
September 13, 2005
Page 1 of 4

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

         DIVISION OF
CORPORATION FINANCE

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