SecProbe.io

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                  PAUL, WEISS, RIFKIND, WHARTON & GARRISON LLP
         FUKOKU SEIMEI BUILDING, 2-2 UCHISAIWAICHO 2-CHOME, CHIYODA-KU,
                             TOKYO 100-0011, JAPAN
            TELEPHONE (813) 3597-8101     FACSIMILE (813) 3597-8120

                                               September 21, 2005

U.S. Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549-3561
Attention:        Mr. Larry Spirgel
                  Assistant Director

                  hanarotelecom incorporated (File No. 1-15012)
                  ---------------------------------------------

Dear Mr. Spirgel:

                  We are submitting this letter on behalf of our client,
hanarotelecom incorporated (the "Registrant"). We appreciate the Staff's
accounting review of the Registrant's previous annual report on Form 20-F for
the fiscal year ended December 31, 2004 filed on June 29, 2005 (the "2004 Form
20-F"), and the Staff's comments with respect to applicable disclosure
requirements and enhanced disclosure in the Registrant's future filings.

                  Set forth below are the comments of the Staff transmitted in
your letter dated September 7, 2005 together with the Registrant's responses to
those comments.

ITEM 15.  CONTROLS AND PROCEDURES, PAGE 88

COMMENT NO. 1.    We note your disclosure that your disclosure controls and
procedures were "effective to ensure that material information required to be
included in our periodic SEC reports relating to us, is made known to them."
Please confirm, if true, and clarify in future filings that your disclosure
controls and procedures are effective in ensuring that information required to
be disclosed in the reports that you file or submit under the Exchange Act is
recorded, processed, summarized and reported, within the time periods specified
in the Commission's rules and forms and are effective in ensuring that
information required to be disclosed in the reports that you file or submit
under the Exchange Act is accumulated and communicated to your management,
including your principal executive and principal financial officers, to allow
timely decisions regarding required disclosure. See Rule 13a-15(e) of the
Exchange Act. Alternatively, you may simply state that your disclosure controls
and procedures are effective.

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U.S. Securities and Exchange Commission                                        2

                  RESPONSE TO COMMENT NO. 1. The Registrant confirms that its
principal executive officer, Mr. Chang-Bun Yoon, and its principal financial
officer, Ms. Janice Lee, after evaluating the effectiveness of the Registrant's
disclosure controls and procedures (as defined in Rule 13a-15(e)) as of the end
of the period covered by the 2004 Form 20-F, concluded that, as of such date,
the Registrant's disclosure controls and procedures were effective. The
Registrant will disclose in its future filings the simple conclusion of its
principal executive and principal financial officers that the Registrant's
disclosure controls and procedures are effective.

COMMENT NO. 2.    We note the statement that "there have been no significant
changes in internal control over financial reporting..." Item 308(c) of
Regulation S-K requires disclosure of any changes, not just significant changes,
in internal controls over financial reporting that would have a material effect
and occurred during the last fiscal quarter. Please confirm, if true, that there
was no change in your internal control over financial reporting that occurred
during your fourth fiscal quarter in 2004 that has materially affected, or is
reasonably likely to materially affect, your internal control over financial
reporting, and provide the disclosure required by Item 308(c) of Regulation S-K
in future filings.

                  RESPONSE TO COMMENT NO. 2. The Registrant confirms that there
have been no changes in its internal controls over financial reporting that
occurred during the fiscal year ended December 31, 2004, that have materially
affected, or are reasonably likely to materially affect, the Registrant's
internal control over financial reporting. In its future filings, the Registrant
will confirm that there have been no changes, or disclose any changes, in its
internal controls over financial reporting as required by Item 15(d) of Form
20-F.

NOTE 1.  GENERAL, PAGE F-11

(2) CONSOLIDATED SUBSIDIARIES

COMMENT NO. 3.    We note that your ownership percentage in Hanaro WEB(n)TV
decreased to 49% as of December 31, 2004. Tell us how you accounted for your
investment in this entity for US GAAP purposes.

                  RESPONSE TO COMMENT NO. 3. In October 2004, the Registrant
disposed of its Hanaro WEB(n) TV shares, which represented a 41.91% ownership
interest, to Media Holdings, Inc., a wholly-owned subsidiary of the Registrant.
As a result, its direct shareholdings in Hanaro WEB(n) TV decreased to 49% as of
December 31, 2004. The Registrant, however, continued to hold a controlling
financial interest through its direct shareholdings of Hanaro WEB(n) TV shares
and indirect ownership (through Media Holdings, Inc.) of Hanaro WEB(n) TV
shares. The direct and indirect shareholdings represents a majority voting
interest, and accordingly consolidated Hanaro WEB(n) TV for the year ended
December 31, 2004 under Korean GAAP as well as under U.S. GAAP.

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U.S. Securities and Exchange Commission                                        3

COMMENT NO. 4.    We note that Hanaro Telecom America, Inc. is in the process of
liquidation and was recognized as impaired at December 31, 2004. Tell us how you
determined whether you were required to present the operations of Hanaro Telecom
America, Inc. as discontinued for US GAAP reporting purposes.

                  RESPONSE TO COMMENT NO. 4. The Registrant resolved to dissolve
Hanaro Telecom America, Inc. as of December 31, 2004. As of such date, the
assets, liabilities and shareholders' equity of Hanaro Telecom America, Inc.
totaled Won 0. In addition, Hanaro Telecom America, Inc. reported a net loss for
the year ended December 31, 2004 of Won 268 million, the nature of which was a
loss from discontinued operation but was not presented as discontinued because
it was considered immaterial. Based on such financial condition and operating
results of Hanaro Telecom America, Inc., the Registrant recorded the entire
amount of investment securities for Hanaro Telecom America, Inc. as an
impairment loss. As a result, the Registrant excluded Hanaro Telecom America,
Inc. from its consolidated financial statements for the year ended December 31,
2004.

NOTE 2.  SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES

INVESTMENT SECURITIES OTHER THAN THOSE ACCOUNTED FOR USING THE EQUITY METHOD,
PAGE F-14

COMMENT NO. 5.    We note your statement that if the realizable value of an
impaired security subsequently recovers, the increase in value is recorded in
current operations up to the amount of the previously recognized impairment
loss, for securities stated at fair value, and up to the amount of amortized
cost that would be recorded if no impairment had occurred, for securities stated
at amortized cost. Explain this statement for us in more detail and tell us how
you determined that it is appropriate to change the new cost basis for
subsequent recoveries in fair value under SFAS 115 for US GAAP reporting
purposes.

                  RESPONSE TO COMMENT NO. 5. Under Korean GAAP, when the amount
estimated to be recoverable is less than the amortized cost of a debt security
or the acquisition cost of an equity security, the Registrant must consider
whether to recognize an impairment loss. The Registrant may recognize a reversal
of impairment loss for an available-for-sale equity security accounted for at
its fair value, when the recovery in fair value is objectively related to an
event occurring after the recognition of impairment loss, and such amount should
be recognized as current income. However, the reversal amount is not permitted
to exceed the amount of impairment loss previously recognized.

                  Under U.S. GAAP, if the decline in fair value is judged to be
other than temporary, the cost basis of the individual security should be
written down to fair value as a new cost basis and the amount of the write-down
must be included in earnings. The new cost basis will not be changed for
subsequent recoveries in fair value. Subsequent

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U.S. Securities and Exchange Commission                                        4

increases in the fair value of available-for-sale securities is included in
other comprehensive income.

                  The Registrant recognizes an impairment loss on
available-for-sale securities when the recoverable value declines to a level
below the acquisition cost in accordance with Korean GAAP. Through December 31,
2004, there have been no cases in which the price of security, for which an
impairment loss was previously recognized, recovered its value. Accordingly, the
Registrant has not considered whether an impairment loss previously recognized
should be reversed, and no adjustments for U.S. GAAP reporting purposes were
necessary in connection with a reversal of impairment loss.

NOTE 12.  INTANGIBLES, PAGE F-23

COMMENT NO. 6.    Tell us and disclose the nature of the cable line usage rights
and how you have acquired these rights. Additionally, tell us how you determined
the useful lives of cable line usage rights to be 20 years.

                  RESPONSE TO COMMENT NO. 6. The nature of the Registrant's
cable line usage rights is the indefeasible right of user ("IRU") for the
submarine cable. The Registrant acquired the IRU from a network service provider
and believes the useful life of such IRU to range from 15 to 20 years in
accordance with Korean business practice. Although the nature of this contract
was an IRU, the estimated useful lives of the cable line usage rights could be
estimated to be specific periods because of the obsolescence and improvement of
the facility and changes in business trends and technologies. In addition, in
certain cases, the contract periods for the cable line usage rights are for
periods ranging from 15 to 20 years, which are consistent with common business
practice.

NOTE 22.  RELATED PARTY TRANSACTIONS, PAGE F-30

COMMENT NO. 7.    Please confirm and disclose in future filings, if true, that
the amounts detailed as significant transactions with your subsidiaries have
been eliminated in consolidation as described in Note 1 (2).

                  RESPONSE TO COMMENT NO. 7. The Registrant confirms that the
amounts disclosed as significant transactions with its subsidiaries have been
eliminated in consolidation as described in Note 1(2). In future filings, the
Registrant will clarify that the amounts detailed as significant transactions
with its subsidiaries have been eliminated in consolidation.

NOTE 23.  COMMITMENTS AND CONTINGENCIES, PAGE F-31

COMMENT NO. 8.    In future filings, revise to discuss the pending fine by the
Korean Fair Trade Commission as disclosed on page 10, including the aggregate
fine of Won 2.4

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U.S. Securities and Exchange Commission                                        5

billion. It appears that this fine relates to the local telephony and leased
line services. Tell us and disclose if you have accrued any amounts related to
this fine as of December 31, 2004. With regard to the fine that has not yet been
determined for the broadband and leased line services, tell us and disclose if
you have accrued any amounts in accordance with SFAS 5 as of December 31, 2004
for US GAAP reporting purposes.

                  RESPONSE TO COMMENT NO. 8. The pending fine by the Korean Fair
Trade Commission (the "KFTC") and the aggregate fine of Won 2.4 billion were not
accrued in the financial statements for the year ended December 31, 2004 because
the fines were imposed by the KFTC in May 2005. Moreover, the KFTC investigation
was initiated during 2005, and as of December 31, 2004, the Registrant had no
expectation that such KFTC investigation would be launched in 2005. The amount
of the pending fine will be accrued in the financial statements for the year
ending December 31, 2005. Under U.S. GAAP, as well as under Korean GAAP, the
Registrant will record the amount of fines imposed by the KFTC as a loss and
fines pending as a loss from contingent liabilities in the year ending December
31, 2005.

NOTE 26.  RECONCILIATION TO ACCOUNTING PRINCIPLES GENERALLY ACCEPTED IN THE
UNITED STATES, PAGE F-33

COMMENT NO. 9.    Disclose the nature of differences in income statement
classification between Korean GAAP and US GAAP and quantify the impact of these
differences in future filings. For example, it appears that the write-off of
property and equipment should be recorded as an operating expense under US GAAP.
In addition, please separately state revenues from net sales of tangible
products and sales of services, if greater than 10% of total revenues. Also,
separately state the costs and expenses applicable to each category of sales and
revenues.

                  RESPONSE TO COMMENT NO. 9. The Registrant understands that,
under U.S. GAAP, income statements are presented with four major categories:
income (or loss) from continuing operation, extraordinary income (or loss),
income (or loss) from discontinued operation, and the effect of accounting
change. In the Registrant's case, the amount of ordinary income (or loss) before
tax represents the amount of income (or loss) from continuing operation that
would be reported under U.S. GAAP for the year ended December 31, 2004, except
for the effect of change in accounting estimates; the change in the useful lives
of tangible assets, effective January 1, 2004, which increased the Registrant's
depreciation by Won 8 million and impairment loss of Won 268 million from
discontinued operation of Hanaro Telecom America, Inc., for the year ended
December 31, 2004. In future filings, the Registrant will disclose the nature of
differences in income statement classification between Korean GAAP and U.S. GAAP
and quantify the impact of these differences.

                  The Registrant has no sales of tangible products, and all of
its revenues relate to sales of services, mostly from its main business service
areas (broadband, voice

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U.S. Securities and Exchange Commission                                        6

and lease of dedicated lines). The Registrant disclosed segment information in
Note 24 of the consolidated financial statements under Korean GAAP and believes
that there are no significant differences in segment information between Korean
GAAP and U.S. GAAP.

LICENSING COST, PAGE F-35

COMMENT NO. 10.   Tell us how you applied the guidance in SFAS 142 in
determining that licensing cost is deemed to have an indefinite life. In
addition, we note your disclosure of the reconciling item related to the license
cost of the NSP license. Tell us how you determined there was no reconciling
item for the other licenses you disclose on page 30.

                  RESPONSE TO COMMENT NO. 10. In Korea, any business entity that
begins as a network service provider ("NSP") or facilities-based
telecommunications service provider must obtain a license from the Ministry of
Information and Communication (the "MIC"). Unless the license is revoked, the
company may operate as a network service provider so long as it continues as an
ongoing business entity.

                  For U.S. GAAP reconciliation purposes, the one-time fee of Won
45.0 billion paid for obtaining the NSP license by the Registrant's founding
shareholders in 1997 was adjusted as licensing cost in the intangible asset
account and simultaneously as a capital injection. The intangible licensing
costs were amortized until 2001 when SFAS 142 became effective for purposes of
U.S. GAAP reconciliation adjus