UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-5546

         DIVISION OF
CORPORATION FINANCE

Mail Stop 5546
								December 29, 2005

Via Facsimile (011) 54 1143 131298 and US Mail

Jose Gustavo Pozzi
General Manager and Sole Officer
Nortel Investments Inc.
Alicia Moreau de Justo 50
Piso 11
C1107AAB Buenos Aires
Argentina

	Re:	Nortel Investments Inc.
		Form 6-K
		Filed December 1, 2005
      Form 20-F for the Fiscal Year Ended December 31, 2004
      Filed June 29, 2005
 		File No. 1-14270

Dear Mr. Pozzi:

      We have limited our review of the above filings to
disclosures
relating to your contacts with countries that have been identified
as
state sponsors of terrorism, and we will make no further review of
the filings.  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
supplemental information so that we may better understand your
disclosure.  Please be as detailed as necessary in your response.
After reviewing this information, we may 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
filings.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.

General

1. We note the reference to Etec S.A. (Cuba) on page 25 of your
Form
6-K filed December 1, 2005.  The table on page 25 states that Etec
S.A. transacts in international calls to and/or from Cuba, which
is
identified as a state sponsor of terrorism by the U.S. State
Department and subject to asset controls administered by the
Treasury
Department`s Office of Foreign Assets Control and the Commerce
Department`s Bureau of Industry and Security.  We note that the
Form
20-F does not contain any information relating to operations in,
or
contacts with, Cuba.  With a view to disclosure, please describe
in
reasonable detail such operations or contacts, and discuss their
materiality to you in light of Cuba`s status as a state sponsor of
terrorism.  Please also discuss whether the operations constitute
a
material investment risk to your security holders.  Your response
should describe your current, historical and anticipated
operations
in, and contacts with, Cuba, including through subsidiaries,
affiliates, joint ventures and other direct and indirect
arrangements.

2. In preparing your response please consider that evaluations of
materiality should not be based solely on quantitative factors,
such
as the approximate dollar amount of revenues, assets and
liabilities
associated with Cuba, but should include consideration of
qualitative
factors that a reasonable investor would deem important in making
an
investment decision, including the potential impact of corporate
activities upon a company`s reputation and share value.  In this
regard, we note that Arizona and Louisiana have adopted
legislation
requiring their state retirement systems to prepare reports
regarding
state pension fund assets invested in, and/or permitting
divestment
of state pension fund assets from, companies that do business with
U.S.-designated state sponsors of terrorism.  We also note that
Florida requires issuers to disclose in their prospectuses any
business contacts with Cuba or persons located in Cuba.  Your
materiality analysis should address the potential impact of the
investor sentiment evidenced by these actions directed toward
companies operating in Cuba.



      Please respond to these comments within 10 business days or
tell us when you will provide us with a response.  Please
understand
that we may have additional comments after reviewing your
amendment
and responses to our comments.  Please file your response letter
on
EDGAR.

      We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings to be certain that the
filings include all information required under the 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 the
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 filing;

staff comments or changes to disclosure in response to staff
comments
do not foreclose the Commission from taking any action with
respect
to the filing; 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 filing or in
response to our comments on your filing.

      Please contact James Lopez at (202) 551-3536 if you have any
questions about the comments or our review.  You may also contact
me
at (202) 551-3470.



								Sincerely,




								Cecilia D. Blye, Chief
								Office of Global Security
Risk




cc: 	Larry Spirgel
 		Kyle Moffatt
Jose Gustavo Pozzi
Nortel Investments Inc.
December 29, 2005
Page 1