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RESIDENT PARTNERS
Lee Edwards
Alan D. Seem
Admitted in New York
Writer's Email Address: December 13, 2006
Alan.Seem@shearman.com
Writer's Direct Number:
+86.10.5922.8002
VIA FACSIMILE
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Ms. Beverly A. Singleton, Staff Accountant
Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549-3561
Tel: +1.202.551.3328
Fax: +1.202.772.9202
RE: GUANGSHEN RAILWAY COMPANY LIMITED
FORM 20-F FOR FISCAL YEAR ENDED DECEMBER 31, 2005
FILED JUNE 29, 2006
FILE NO. 1-14362
Dear Ms. Singleton:
We refer to our letter dated November 27, 2006 in which we requested on
behalf of our client, Guangshen Railway Company Limited ("Guangshen"), for an
extension of the deadline for responding to your letter commenting on
Guangshen's Form 20-F for the fiscal year ended December 31, 2005. Guangshen's
management has continued to devote significant resources to respond to the
comments from the Staff and some of the responses require further work,
including discussions with Guangshen's reporting accountants, to ensure the
Staff's concerns are properly addressed. Therefore, Guangshen has asked us to
request on their behalf a further extension of the deadline for responding to
Janaury 15, 2007. Guangshen would be grateful if the Staff could accommodate
this request.
* * * *
Please direct any questions concerning this letter to the undersigned at
+86.10.5922.8002.
Very truly yours,
/s/ Alan Seem
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Alan Seem
cc: Margery E. Reich, Senior Staff Accountant
David R. Humphrey, Branch Chief
Securities and Exchange Commission
Mr. Yao Xiaocong
Mr. Guo Xiangdong
Guangshen Railway Company Limited