SecProbe.io

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

       DIVISION OF
CORPORATION FINANCE

Mail Stop 3720
 January 24, 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. 6 to Registration Statement on Form SB-2 Filed January 17, 2008
  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.
 Calculation of Registration Fee

 1. We note your disclosure in footnote (3) to the fee table that no ne of the shares
registered for sale are to be received  by the selling shareholders for liquidated
damages, conversion default payments or mandatory redemption obligations.  Please explain in an appropriate location of your prospectus the provisions of the notes and warrants pursuant to which th e additional 30% of each category of
underlying common shares could potentially  be issued.  Advise us why the

Yankuan Li
Guangzhou Global Telecom, Inc.
January 24, 2008 Page 2

registration rights agreement requires the company to register 130% of the total
number of shares issuable upon conversion of the debentures, upon exercise of the
warrants notes and as payment of interest .
 2. We note your registration of 130% of th e 1,530,140 shares which will be issued to
make interest payments on the notes.  In an appropriate location of your
prospectus, please explain the calculation of this amount of interest shares.  You
note in footnote (5) that $0.82 is the assumed interest conversion price.  Tell us why you used this price to determine the number of interest shares to register
considering the relevant pr ovisions of the registration rights agreement and the
fact that the last reporte d sales price of your common stock as disclosed on the
cover page of your prospectus was $0.27.  Please ensure that you reconcile your
revised prospectus disclosure with the maximum possible interest payments of
$742,572.45 disclosed in column (3) to your table on page five (and elsewhere in your tabular disclosure) and the total possible shares is suable to pay interest on
the notes of 308,891 disclosed in column (3 ) to your table on the top of page
eight.

Prospectus Cover Page

3. Your prospectus cover page does not identify  all of the shares being registered for
sale.  Please revise to identify all of the shares being offered, both in the aggregate
and for each category of underlying common shares.
 Disclosure Regarding Our Recent Financing and Conversion of Notes and Exercise of
Warrants, page 1
 Terms of Financing Documents, page 1

 Securities Purchase Agreement, page 1

 4. We note the disclosure on page two of the company’s belief that it will be able to
meet the effective date deadline in the re gistration rights agreement.  Since, based
on your current disclosure, it appears that this deadline has already passed, please
explain this belief or revi se accordingly.  Clearly e xplain any consequences of
your failure to meet this deadline.
 Note, page 3

5. Please revise your disclosure to explain how  the interest share conversion price is
determined.  Based on your disclosure else where in the prospectus and the terms
of the convertible notes, it appears that the interest share conversion price would
be the lesser of $0.82 and a discounted mark et price.  Your current disclosure
does not explain this determination and, to the contrary, indicates that the interest
share conversion price does not fluctuate or adjust.

Yankuan Li
Guangzhou Global Telecom, Inc.
January 24, 2008
Page 3

6. In your description of the monthly redemption terms of the notes, clarify, if true, that this is a mandatory obligation of the company.
 Value of Underlying Shares, page 4

 7. Since the company is registering the offering of more than 4,181,184 shares of common stock underlying the notes, pleas e revise this paragraph accordingly.
 Selling Stockholders, page 13

 8. Please revise column (1) to provide th e numbers of shares of common stock
owned prior to the offering.  Refer to Regulation S-B 507 and 403 and the
instructions thereto.  You have indicated th at the selling share holders beneficially
own (or have the right to acquire within 60 days) all of the shares registered to be
offered, but this does not appear to be the case.

* * * *

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, Attorney-Adviser, at 202-551-3576, 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