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                             METZGER & McDONALD PLLC
                    (formerly Prager, Metzger & Kroemer PLLC)
                    A PROFESSIONAL LIMITED LIABILITY COMPANY
                        ATTORNEYS, MEDIATORS & COUNSELORS

STEVEN C. METZGER          2626 COLE AVENUE, SUITE 900
DIRECT DIAL 214-740-5030    DALLAS, TEXAS 75204-1083      FACSIMILE 214-523-3838
SMETZGER@PMKLAW.COM               214-969-7600                      214-969-7635
                                 WWW.PMKLAW.COM






                                   May 6, 2005


The Securities and Exchange Commission
450 Fifth Street, N.W.
Judiciary Plaza
Washington, D.C. 20549

         Re:      CabelTel  International   Corporation,   CIK  No.  0000105744;
                  Commission File No. 000-08187

Gentlemen:

         On behalf of CabelTel International Corporation,  we are delivering for
filing  with the  Commission  Amendment  No. 3 to Form 10-K for the fiscal  year
ended  December  31, 2004.  Amendment  No. 3 is filed under cover of Form 10-K/A
amending  the  original  filing  in  order  to  correct  minor   references  and
typographical  errors on several  pages,  which  includes an  explanation of the
changes and attaches  replacement  pages for  inclusion in the Form 10-K bearing
the same page  numbers as the  original  pages.  The  enclosed  filing  does not
materially  change any information in the original Form 10-K as filed,  nor does
it involve any restatement of any financial information.

         Any questions  relating to the enclosed  filing may be addressed to the
undersigned at the address and telephone set forth above or to Gene S. Bertcher,
President and Chief  Financial  Officer of the  Registrant  at the  Registrant's
principal executive office address or at 972-407-8400.

                                                  Very truly yours,

                                                  /s/ Steven C. Metzger

                                                  Steven C. Metzger

SCM:ag
Enclosure

cc:      Gene S. Bertcher
         President and Chief Financial Officer
         CabelTel International Corporation
         1755 Wittington Place, Suite 340
         Dallas, TX 75234

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