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SEC Company Response from CHINA UNICOM LTD (CIK 0001113866) — Aug 5, 2005

CHINA UNICOM LTD (CIK 0001113866)
Date: Aug. 5, 2005 · CIK: 0001113866 · Accession: 0001104659-05-036744

AI Filing Summary & Sentiment

Referenced dates: July 29, 2005

Date
August 5, 2005
Author
Assistant Director
Form
CORRESP
Company
CHINA UNICOM LTD (CIK 0001113866)

Letter

Division of Corporation Finance Securities and Exchange Commission Washington, DC 20549 United States of America Re: Annual Report on Form 20-F for the Fiscal Year ended December 31, 2004 (File No. 1-15028)

Dear Mr. Spirgel:

China Unicom Limited (the “Company”) has received the comment letter from the staff dated July 29, 2005 relating to the Company’s Annual Report on Form 20-F for the fiscal year ended December 31, 2004 (the “Form 20-F”), which was filed with the Securities and Exchange Commission on June 28, 2005. On behalf of the Company, we wish to thank you and the other members of the staff for taking the time to review the Form 20-F and for providing us with your helpful comments.

The Company notes that the staff has requested that the Company either: (i) amend the Form 20-F in response to the staff’s comments and respond to these comments within 10 business days or (ii) inform the staff as to when the Company will provide a response to these comments. The Company has carefully reviewed and considered the staff’s comments, and is in the process of preparing a response to these comments. Regrettably, the Company believes that it will not be in a position to respond to all of the staff’s comments within 10 business days. However, the Company expects that it will be in a position to respond to all of the staff’s comments by August 26, 2005, and would be grateful if the staff could accommodate the Company in this regard.

Mr. Larry Spirgel

Thank you again for your time. Please feel free to contact Jackson Yee (Company Secretary) at 852-2121-3220 with any questions you may have.

Very truly yours,
/s/ Tong Jilu

Show Raw Text
CORRESP
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CHINA UNICOM LIMITED (Stock Code: 762)

(Incorporated in Hong Kong
with limited liability under the Hong Kong Companies Ordinance)

August 5, 2005

By Facsimile

Mr. Larry Spirgel

Assistant Director

Division of Corporation Finance

Securities and Exchange Commission

100 F Street, N.E.

Washington, DC 20549

United States of America

Re:                               Annual
Report on Form 20-F for the Fiscal Year

ended December 31, 2004 (File No. 1-15028)

Dear Mr. Spirgel:

China Unicom Limited (the “Company”) has received the
comment letter from the staff dated July 29, 2005 relating to the Company’s
Annual Report on Form 20-F for the fiscal year ended December 31,
2004 (the “Form 20-F”), which was filed with the Securities and Exchange
Commission on June 28, 2005. On behalf of the Company, we wish to thank
you and the other members of the staff for taking the time to review the Form 20-F
and for providing us with your helpful comments.

The Company notes that the staff has requested that
the Company either: (i) amend the Form 20-F in response to the staff’s
comments and respond to these comments within 10 business days or (ii) inform
the staff as to when the Company will provide a response to these comments. The
Company has carefully reviewed and considered the staff’s comments, and is in
the process of preparing a response to these comments. Regrettably, the Company
believes that it will not be in a position to respond to all of the staff’s
comments within 10 business days. However, the Company expects that it will be
in a position to respond to all of the staff’s comments by August 26, 2005,
and would be grateful if the staff could accommodate the Company in this
regard.

Mr. Larry Spirgel

Thank you again for your time. Please feel free to
contact Jackson Yee (Company Secretary) at 852-2121-3220 with any questions you
may have.

  Very truly yours,

  /s/ Tong Jilu

  TONG Jilu

  Chief Financial Officer

  cc:

  Ivette Leon

  Kathryn Jacobson

  Cheryl Grant

  (Securities and Exchange Commission)

  Jackson Yee

  (China Unicom Limited)

  Elton Yeung

  Stephen Wong

  Daniel Hu

  (PricewaterhouseCoopers)

  Chun Wei

  Calvin Lai

  (Sullivan & Cromwell LLP)