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

         DIVISION OF
CORPORATION FINANCE

Mail Stop 5546
								March 22, 2006

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 reviewed your letter dated January 19, 2006 and have
the following comments.  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.  Feel free to call us at the telephone numbers
listed
at the end of this letter.

General

1. We note your response to our prior comments.  In light of your
statement that you have "no direct or indirect ownership interest
in
Etec," please explain the aspects of your relationship with Etec
whereby it may be deemed a related party of Nortel Inversora.

2. In light of the statement in your response that Etec may be
deemed
a related party, and in light of Cuba`s status as a country
identified by the U.S. as a state sponsor of terrorism and subject
to
OFAC-administered asset controls, please address the qualitative
materiality of your relationship with Etec in conjunction with
Etec`s
role in Cuba`s infrastructure, including its status as the
exclusive
operator for national and international fixed line
telecommunications
services in Cuba.


      Please understand that we may have additional comments after
reviewing your responses to our comments.

      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.
March 22, 2006
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