Securities Exchange Act of 1934
Rule 12g-3

February 27, 2009

RESPONSE OF THE OFFICE OF INTERNATIONAL CORPORATE FINANCE
DIVISION OF CORPORATION FINANCE

Based on the facts presented, the Division's views are as follows. Capitalized terms have the same meanings defined in your letter.

• The reporting history of HTCC Delaware under the Exchange Act may be taken into account to determine whether Invitel Denmark is eligible to use Form S-8 under the Securities Act;

• HTCC Delaware's Exchange Act reporting history may be taken into account when determining Invitel Denmark's compliance with the current public information requirements of Rule 144(c)(1) under the Securities Act;

• Average weekly reported trading volume in HTCC Delaware Common Stock during the time periods specified by Rule 144(e)(1) may be taken into account in determining the limitations on the amount of securities that may be sold pursuant to Rule 144(e);

• The Merger will be a "succession" for purposes of Rule 12g-3(a) under the Exchange Act and Invitel Denmark will be an "accelerated filer" for purposes of Rule 12b-2 under the Exchange Act;

• Persons who have filed statements on Schedule 13D or 13G under the Exchange Act reporting beneficial ownership of HTCC Delaware Common Stock will not be required to file additional or amended statements on Schedule 13D or 13G as a result of the Merger, provided that they note in their next subsequent filings on Schedule 13D or 13G that Invitel Denmark is the successor to HTCC Delaware.

These positions are based on the representations made to the Division in your letter. Different facts or conditions might require different conclusions.

Incoming Letter:

The Incoming Letter is in Acrobat format.

http://www.sec.gov/divisions/corpfin/cf-noaction/2009/
hungariantelephone022709-12g3.htm