J.P. Morgan Securities Inc.
277 Park Avenue
New York, NY 10172
December 7, 2005
Re: WIDERTHAN CO., LTD.
REGISTRATION STATEMENT ON FORM F-1 VIA FACSIMILE
REGISTRATION FILE NO. 333-129806
Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, D.C. 20549
(202) 772-9209
Dear Sir/Madam:
Pursuant to Rule 460 of the General Rules and Regulations under the
Securities Act of 1933 (the "ACT"), the undersigned, as representative of the
several Underwriters, wish to advise you that the Preliminary Prospectus issued
November 18, 2005 were distributed between November 18, 2005 through 5:00 p.m.,
Eastern Standard Time, December 6, 2005, as follows:
<Table>
<Caption>
PRELIMINARY PROSPECTUS
----------------------
13,099 copies to 3 Underwriters
0 copies to 0 Dealers
2,768 copies to 692 Institutions
2 copies to 2 Others
Total: 15,869 copies
</Table>
We have been informed by the participating underwriters that they will
comply with the requirements of Rule 15c2-8 under the Securities Exchange Act of
1934.
In accordance with Rule 461 of the Act, we hereby join in the request of
WiderThan Co., Ltd. that the effective date of the above-named Registration
Statement be accelerated to 5:00 p.m. Eastern Standard Time on December 8, 2005,
or as soon thereafter as practicable.
We were advised on December 6, 2005 by the Corporate Financing Department
of the National Association of Securities Dealers, Inc. that it has reviewed the
above-captioned proposed offering and that it has determined to raise no
objections with respect to the fairness of the terms and arrangements of the
offering.
Securities and Exchange Commission 2 December 7, 2005
Very truly yours,
J.P. MORGAN SECURITIES INC.
By: /s/ RICHARD SESNY
---------------------------------------
Name: Richard Sesny
Title: Vice President
Acting on behalf of itself and the several
Underwriters