July 27, 2018

Via E-mail
Jung Ho Park
President and Chief Executive Officer
SK Telecom Co., Ltd.
SK T-Tower
65, Eulji-ro, Jung-gu, Seoul, Korea

       Re:     SK Telecom Co., Ltd.
               Form 20-F for the Fiscal Year Ended December 31, 2017
               Filed April 27, 2018
               File No. 333-04906

Dear Mr. Park:

        We have limited our review of your filing to your contacts with
countries that have been
identified as state sponsors of terrorism, and we have the following comment.
Our review with
respect to this issue does not preclude further review by the Assistant
Director group with respect
to other issues. At this juncture, we are asking you to provide us with
information so we may
better understand your disclosure.

       Please respond to this letter within ten business days by providing the
requested
information, or by advising us when you will provide the requested response. If
you do not
believe our comment applies to your facts and circumstances, please tell us why
in your
response.

       After reviewing the information you provide in response to this comment,
we may have
additional comments.

General

   1. On your website you list the international calling rates for Sudan and
Syria, countries that
      are designated by the U.S. Department of State as state sponsors of
terrorism and are
      subject to U.S. economic sanctions and/or export controls. It appears
from your website
      that you also may offer additional telecom services related to those
countries. Your Form
      20-F does not include disclosure about contacts with those countries.
Please provide us
      with information regarding your contacts with Sudan and Syria, if any,
whether through
      subsidiaries or other direct or indirect arrangements. You should
describe any services
      you have provided into Sudan and Syria, directly or indirectly, and any
agreements,
      arrangements or other contacts you have had with the governments of Sudan
and Syria or
      entities they control. Please also discuss the materiality of those
contacts, in quantitative
 Jung Ho Park
SK Telecom Co., Ltd.
July 27, 2018
Page 2

       terms and in terms of qualitative factors that a reasonable investor
would deem important
       in making an investment decision. Tell us the approximate dollar amounts
of revenues,
       assets and liabilities associated with Sudan and Syria for the last
three fiscal years and the
       subsequent interim period. Address for us the potential impact of the
investor sentiment
       evidenced by divestment and similar initiatives that have been directed
toward companies
       that have operations associated with U.S.-designated state sponsors of
terrorism.

        We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence of
action by the staff.

        Please contact Pradip Bhaumik, Special Counsel, at (202) 551-3333 or me
at (202) 551-
3470 if you have any questions about the comment or our review.

                                                              Sincerely,

                                                              /s/ Cecilia Blye

                                                              Cecilia Blye,
Chief
                                                              Office of Global
Security Risk


cc:    Larry Spirgel
       Assistant Director
       Division of Corporation Finance