SecProbe.io

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      							March 22, 2005

Mail Stop 0406

Mr. Finbarr J. O`Neill
President and Chief Executive Officer
The Reynolds and Reynolds Company
One Reynolds Way
Dayton, Ohio 45430

	RE:	The Reynolds and Reynolds Company
      File no. 001-10147
		Form 10-K: For the Year Ended September 30, 2004
		Form 10-Q: For the Quarterly Period Ended December 31,
2004

Dear Mr. O`Neill:

	We have reviewed the above referenced filings and have the
following comments.  Please note that we have limited the scope of
our review to certain accounting policies and practices in your
financial statements and related disclosures.  Where indicated, we
think you should revise your documents in response to these
comments.
If you disagree, we will consider your explanation as to why our
comment is inapplicable or a revision is unnecessary.  Please be
as
detailed as necessary in your explanation.  In some of our
comments,
we may ask you to provide us with supplemental information so we
may
better understand your disclosure.  After reviewing this
information,
we may or may not 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 comments or on any other aspect
of
our review.  Feel free to call us at the telephone numbers listed
at
the end of this letter.

Annual Report on Form 10-K for the Year Ended September 30, 2004

Item 7. Management Discussion and Analysis of Financial Condition
and
Results of Operations

Services, page 15

1. We note that 2004 Services revenue declined, in part, because
of
the loss of a customer and that 2004 and 2003 Documents sales
declined, in part, because of a decrease in volume and price (page
16).  Tell us the amount that revenue decreased due to the loss of
this customer and due to changes in volume and pricing.  Tell us
what
consideration you gave to discussing the impact of these events
and
fluctuations caused by changes in volume and price.  We refer you
to
Regulation S-K, Rule 303(a)(3)(i) and 303(a)(3)(iii).

Consolidated Balance Sheets, page 35

2. We note that you segregate your Consolidated Balance Sheets and
your Statements of Condensed Consolidated Cash Flows between
automotive solutions and financial services.  Your presentation
does
not appear to fully comply with the provisions of Articles 3-01(a)
and 3-02(a) of Regulation S-X.  Revise future filings to present
your
Consolidated Balance Sheets and Statements of Condensed
Consolidated
Cash Flows on a consolidated basis without segregating automotive
solutions and financial services assets, liabilities and cash
flows.
We would not object to you also including balance sheets and cash
flows as currently presented with appropriate headings, such as
supplementary balance sheets and cash flows, in your financial
statements.  If you choose to present segregated balance sheets
and
cash flows, those financial statements should follow your
consolidated balance sheets and consolidated cash flows.

3. We note that your other current assets, other assets and other
current liabilities have significant balances at the end of each
year
presented.  Tell us what is included in these balances and the
related amounts. Tell us what consideration you gave to the
following.
* Stating separately any other current asset that is in excess of
five percent of total current assets, in accordance with
Regulation
S-X, Rule 5-02(8).
* Stating separately any other asset that is in excess of five
percent of total assets, in accordance with Regulation S-X, Rule
5-
02(17).
* Stating separately any other current liability that is in excess
of
five percent of total current liabilities, in accordance with
Regulation S-X, Rule 5-02(20).

Note 1. Summary of Significant Accounting Policies

Revenue Recognition, page 40

4. We note your disclosure with regard to arrangements that
contain
multiple elements.  Tell us whether you apply the provisions of
EITF
00-21 and/or SOP 97-2 (including SOP 98-9) to your multiple
element
arrangements.   Further, tell us how you have established fair
value
for each element in your multiple element arrangements including
but
not limited to services, hardware, documents and financial
services.
As it relates to your financial services arrangements specifically
address how you determine the fair value of the interest rate on
your
loans to customers and products being financed.

5. We note from your disclosure that software revenues not meeting
the criteria discussed in EITF 00-3 are recorded ratably over the
contract period.  Further explain this disclosure and your
"software
revenues" that are subject to the provisions of EITF 00-3.  In
this
regard tell us how you account for and how your disclosure
addresses
software arrangements that include hosting services and those that
do
not, and the authoritative literature that you apply.

6. Tell us where you classify your revenues from hosting services
in
your Statements of Consolidated Income.  In your response provide
your hosting revenues for all periods presented.

7. With respect to your financing revenue disclosure, tell us the
products and services that you are financing and when you
recognize
revenue for those products and services.  If you are providing
your
customers financing for software, tell us whether this results in
incremental risk that you will provide a refund or concession to
your
customer.  If yes, tell us how you have considered your
participation
in customer financing in determining that fees are fixed and
determinable and how this impacts your revenue recognition.  We
refer
you to TPA 5100.61-64.  Tell us what consideration you gave to
disclosure of your revenue recognition for products and services
that
are financed.

8. We note that your provision for credit memos reported in your
schedule of qualifying accounts and that it is in excess of $25
million for all years presented.  Considering the significance of
your credit memos, tell us what consideration you gave to
disclosing
whether your arrangements include provisions for returns or
refunds.
Address whether your rights of return or refund impact the fixed
or
determinable nature of your fees and your revenue recognition for
products and services.  We refer you to SFAS 48 and paragraph 31
of
SOP 97-2.

Note 7.  Financing Arrangements

9. We note your disclosure with respect to your financing
arrangements.  Supplementally tell us the general character, rate
of
interest, date of maturity, and contingent and convertible
features
of each type of your long-term debt in accordance with Regulation
S-X
Rule 5-02(22).  Explain to us what consideration you gave to
disclosures under Regulation S-X, Rule 5-02(22) and (23).

Note 12.  Segment Reporting

10. We note you are planning on combining the software solutions
and
services segments in fiscal year 2005.  Tell us how you have
considered each of the aggregation criteria in paragraph 17, of
SFAS
131, in determining that it is appropriate to combine these
segments.
Further, if you meet the criteria to aggregate your segments,
ensure
to disclose the entity-wide information for products and services
revenues in future filings.  We refer you to paragraph 37 of SFAS
131.

*****

	 We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing reviewed by the staff to
be
certain that they have provided all information investors require
for
an informed decision.  Since the company and its management are in
possession of all facts relating to a company`s disclosure, they
are
responsible for the accuracy and adequacy of the disclosures they
have made.

	In connection with responding to our comment, please provide,
in
writing, a statement from the company acknowledging that:

* The company is responsible for the adequacy and accuracy of the
disclosure in the filing;

* Staff comments or changes to disclosure in response to staff
comments do not foreclose the Commission from taking any action
with
respect to the filing; and

* The company may not assert staff comments as a defense in any
proceeding initiated by the Commission or any person under the
federal securities laws of the United States.

      In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in our review of your filing or in
response to our comments on your filing.

	Please respond to these comments within 10 business days and
file your response letter via EDGAR.  Please understand that we
may
have additional comments after reviewing your responses to our
comments.

You may contact Christopher White, Staff Accountant, at (202) 942-
8645, Thomas Ferraro, Review Accountant, at (202) 824-5367 or me
at
(202) 942-2949 if you have any questions regarding these comments.

							Very truly yours,

							Craig Wilson
							Senior Assistant Chief
Accountant

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The Reynolds and Reynolds Company
March 17, 2005
page 1

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