Mail Stop 3561

      							September 7, 2005


Ms. Janice Lee
Executive Vice President and Chief Financial Officer
hanarotelecom incorporated
Tae-pyung-ro 2-43
Chung-ku, Seoul 100-733
Korea

	Re:	hanarotelecom incorporated
      Form 20-F for Fiscal Year Ended December 31, 2004
		Filed June 29, 2005



Dear Ms. Lee:

      We have reviewed your filing and have the following
comments.
We have limited our review to only your financial statements and
related disclosures and do not intend to expand our review to
other
portions of your documents.  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
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 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 Fiscal Year Ended December 31, 2004

Item 15.  Controls and Procedures, page 88

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.

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.

Note 1.  General, page F-11

(2) Consolidated Subsidiaries

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.

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.




Note 2.  Summary of Significant Accounting Policies

Investment Securities Other than those Accounted for Using the
Equity
Method, page F-14

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.

Note 12.  Intangibles, page F-23

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.

Note 22.  Related Party Transactions, page F-30

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).

Note 23.  Commitments and Contingencies, page F-31

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 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.

Note 26.  Reconciliation to Accounting Principals Generally
Accepted
in the United States, page F-33

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.

Licensing Cost, page F-35

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 for the NSP license. Tell us how you determined
there was no reconciling item for the other licenses you disclose
on
page 30.

Investment Securities, page F-35

11. Tell us how you have determined that your long-term available
for
sale securities were not impaired as of December 31, 2004.  In
this
regard, we note that a significant amount of these investments
have
had unrealized losses in excess of  12 months.

Segment Information, page F-42

12. Tell us and disclose the amounts recorded for goodwill for
each
segment.  In addition, tell us how you determined your reporting
units under SFAS 142 and disclose your policy for testing goodwill
for impairment for US GAAP reporting purposes.  If there is
goodwill
assigned to the Voice segment, tell us how you have determined
that
no impairment exists given the ongoing operating loss of this
segment.

*    *    *    *

      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 information.  Detailed letters greatly facilitate our
review.  Please understand that we may have additional comments
after
reviewing your responses to our comments.

	We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing to be certain that the
filing includes all information required under the Securities
Exchange Act of 1934 and that they have provided all information
investors


require for an informed investment 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 Kathleen Kerrigan, Staff Accountant, at
(202)
551-3369 or Melissa Hauber, Senior Staff Accountant, at (202) 551-
3368 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,



								Larry Spirgel
								Assistant Director


Ms. Janice Lee
hanarotelecom incorporated
September 7, 2005
Page 5