Comment letter

ƒDeutsche Telekom T April 1, 2005 Jonathan G. Katz, Secretary U.S. Securities and Exchange Commission 450 Fifth Street, NW Washington, DC 20549-0609 Re: Roundtable on Implementation of Internal Control Reporting Provisions File Number 4-497 Dear Mr. Katz: We appreciate the opportunity to participate in the roundtable discussion and to continue our dialogue with the Commission on this very important subject. We commend the Commission’s efforts and sensitivity on behalf of foreign private issuers, and we believe that the current cooperative environment should result in a balance between sensible, cost-effective regulation and investor protection. Compliance Costs Exceed Expectations Deutsche Telekom AG is a large organization with over 400 subsidiaries and 250,000 employees located throughout approximately 65 countries. Like other large public companies, the costs that has incurred and the efforts it has made to comply with the Sarbanes-Oxley Act of 2002 and related regulations, particularly Section 404, have been considerable and have far exceeded expectations. The Commission stated in its final rules release regarding management reports on internal control that these rules will increase costs for all reporting companies, but that such costs would be mitigated somewhat because companies already have an existing obligation to maintain an adequate system of internal accounting control ...