SecProbe.io

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<TYPE>LETTER
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<FILENAME>filename1.txt
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Room 4561
December 1, 2005

Mr. Warren D. Edwards
Executive Vice President and Chief Financial Officer
Affiliated Computer Services, Inc.
2828 North Haskell
Dallas, TX 75204

      Re:	Affiliated Computer Services, Inc.
      Form 10-K for Fiscal Year Ended June 30, 2005
		Filed September 13, 2005
		Form 10-Q for Fiscal Quarter Ended September 30, 2005
		Filed November 9, 2005
      Form 8-K Filed October 20, 2005
      File No. 1-12665

Dear Mr. Edwards,

      We have reviewed your response letter dated October 18, 2005
and have the following additional comments.  We may ask you to
provide us with supplemental information so we may better
understand
your disclosure.  Please be as detailed as necessary in your
explanation.  After reviewing this information, we may raise
additional comments.

      Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comment or on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.

Form 10-K for Fiscal Year Ended June 30, 2005

Consolidated Financial Statements

Consolidated Statements of Income, page 46
1. We have read your response to prior comment number 1.
Notwithstanding the reasons identified in your response, we
believe
that you are required to comply with the provisions of Item 5-
03(2)
of Regulation S-X.  We believe that this will provide meaningful
information and note that substantially all of your competitors
listed on page 7 of your 2005 Form 10-K comply with this
requirement.
We further believe that complying with Item 5-03 will not
sacrifice
transparency and note that you will be able to retain your
operating
income caption.  In addition, providing a view of operations
"through
management`s eyes" and presenting information used by management
to
evaluate results may be accomplished through MD&A disclosure as
indicated in Section I.B of SEC Release 33-8350 and in segment
data
in accordance with SFAS 131.  Please revise your presentation to
comply.

Note 22. Quarterly Results of Operations (unaudited), page 79
2. We have read your response to prior comment number 2 and do not
believe it is appropriate for you to rely on SAB Topic 6.G that is
intended to allow registrants in specialized industries to modify
their presentations.  We do not believe that your industry is
specialized to the extent that a measure of gross profit is not
required.  In addition, we note that reporting gross profit does
not
preclude you from continuing to present operating income within
these
disclosures.  Please revise your presentation to comply.

Form 8-K Filed October 20, 2005
3. We have read your response to prior comment number 3 and note
that
you refer to the narrative disclosures made in the "Use of Non-
GAAP
Financial Information" section of your earnings release regarding
adjusted diluted earnings per share.  As these disclosures appear
to
be very brief and general, it is unclear how you have provided
each
disclosure described in Question 8 of the Frequently Asked
Questions
Regarding the Use of Non-GAAP Financial Measures.  Please explain
to
us how you have complied with this guidance considering you are
excluding items that you describe as "infrequently occurring."

4. Please clarify for us how your calculation of "internal growth"
addresses revenue ramp-up from new business entered into by an
acquired company prior to the acquisition date.  Indicate whether
the
calculation results in you considering revenue increases related
to
such contracts to be internal growth because the revenue had not
yet
been fully included in the pre-acquisition revenue.  If these
revenue
increases are considered "internal growth," please explain to us
why
you have not provided clarifying disclosures so that readers
understand this and do not confuse "internal growth" with other
measures of growth.

Form 10-Q for Fiscal Quarter Ended September 30, 2005
5. We note that you adopted SFAS 123(R) during the quarter ended
September 30, 2005.  Please explain to us how you considered
disclosure of the following:

* The impact, if any, of estimating forfeitures on stock-based
compensation expense recorded after adoption related to options
that
were granted prior to adoption.  As part of your response,
indicate
how forfeitures were treated in your pre-adoption pro forma
disclosures;
* How you established the beginning balance of the additional
paid-in
capital pool related to the tax effects of employee stock-based
compensation;
* The effect, if any, of the adoption on the mechanics of your EPS
calculations (e.g., determination of assumed proceeds);
* How you determined that relying exclusively on historical
information to estimate volatility was appropriate; and
* The reasons for the decrease in the expected term since the
first
quarter of fiscal 2004.

      As appropriate, please respond to these comments within 10
business days or tell us when you will provide us with a response.
Please submit all correspondence and supplemental materials on
EDGAR
as required by Rule 101 of Regulation S-T.  You may wish to
provide
us with marked copies of any amendment to expedite our review.
Please furnish a cover letter with any amendment that keys your
responses to our comments and provides any requested information.
Detailed cover letters greatly facilitate our review.  Please
understand that we may have additional comments after reviewing
any
amendment and your responses to our comments.

      You may contact Mark Kronforst at (202) 551-3451 or me at
(202)
551-3489 if you have any questions regarding these comments.

							Very truly yours,

							Brad Skinner
						Accounting Branch Chief
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Warren D. Edwards
Affiliated Computer Services, Inc.
December 1, 2005
Page 4

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