SecProbe.io

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

       DIVISION OF
CORPORATION FINANCE

Mail Stop 3720
 January 4, 2008
  Yankuan Li Chief Executive Officer and Chairman of the Board Guangzhou Global Telecom, Inc. c/o Corporation Service Company 1201 Hays Street Tallahassee, FL 32301
Re: Guangzhou Global Telecom, Inc.
Amendment No. 3 to Registration Statement on Form SB-2 Filed December 28, 2007
  File No. 333-145858  Dear Mr. Li:

We have limited our review of your filing to  the matters set forth in the comments
below.  Where indicated, we think you should revise your documents in response to these
comments.  If you disagree, we will consider your explanation as to why our comment is
inapplicable or a revision is unnecessary.  Pl ease 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 re view 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.

Disclosure Regarding Our Recent Financing and Conversion of Notes and Exercise of
Warrants, page 2

Note, page 3

1. We note your revised disclosure in the la st two sentences of the paragraph titled
“Interest, Maturity and Conversion” in response to comment three in our letter
dated December 18, 2007.  Please further re vise to clarify how the number of

Yankuan Li
Guangzhou Global Telecom, Inc.
January 4, 2008 Page 2

Interest Shares will be determined (i.e., what stock price will be used to compute
the number of shares that is equal to th e dollar amount of the interest payment).
Also explain what Interest Conversion Shares are and how they differ from
Interest Shares.
 2. We reissue comment two in our letter dated December 18, 2007 with respect to your description of the anti-dilution provisions of the notes on page 4.
 Total Possible Profit Selling Shareholders Could Realize as a Result of the Interest
Conversion Discount, page 7
 3. Refer to the column “Total Possible Shares  Issuable to Pay Interest on the Notes”
and the accompanying footnote (3).  It is unclear how 207,698 shares would
satisfy interest payments of $253,291 base d on an interest conversion price of
$0.82.  Revise columns (3), (4), (5) and (6) as appropriate.
 Executive Compensation, page 26

 4. Please revise to provide updated Item 402 disclosure covering the fiscal year
ended December 31, 2007.

* * * *

As appropriate, please amend your regist ration statement in response to these
comments.  You may wish to provide us with marked copies of the amendment to expedite our review.  Please furnish a cove r letter with your amendment that keys your
responses to our comments and provides any requested supplemental information.
Detailed cover letters greatly facilitate our review.  Please understa nd that we may have
additional comments after reviewing your amendment and responses to our comments.
 You may contact John Harrington, Atto rney-Adviser, at 202-551-3576, Kathleen
Krebs, Special Counsel, at 202-551-3810, or  me, at 202-551-3810, with any questions.

     S i n c e r e l y ,          /s/ Michele Anderson
     L e g a l  B r a n c h  C h i e f

 cc: Richard I. Anslow, Esq.  Anslow & Jaclin, LLP  Via facsimile: (732) 577-1188

Yankuan Li
Guangzhou Global Telecom, Inc.
January 4, 2008
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