That's over a quarter of the country's smartphone owners.
Morgan Stanley analyst Katy Huberty issued a note to investors predicting that Apple will make its iPhone available through China Telecom and China Mobile in the next year.
That would make it available on all three networks (it's with China Unicom already), and could add an extra 26m sales in 2013 to bring the total to 40m.
She reckons Apple would only reach ten per cent of the 150 million "high-end Chinese subscribers" on one network.
China Mobile alone has an estimated 120 million customers who pay more than 100RMB ($16) a month.
Morgan Stanley expects the next-generation iPhone to arrive in the third quarter of 2012 and a China Mobile iPhone launch to occur in late 2012 or early 2013.