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June 10, 2005

Craig Wilson
Senior Assistant Chief Accountant
U.S. Securities and Exchange Commission
Division of Corporation Finance
Washington, D.C. 20549

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. Wilson,

The following comments are in response to the staff's additional comment letter
dated May 17, 2005. For convenience of reference, our responses are organized
using the same headings and numbered captions as your letter.

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

Consolidated Balance Sheets, page 35

Prior Comment no. 2

1.    Comment

      We have considered your response to our prior comment no. 2 and do not
      find your reasons for omitting a consolidated balance sheet and statement
      of cash flows persuasive. As previously requested, revise future filings
      to present consolidated balance sheets and statements of cash flows
      without segregating your automotive solutions and financial services
      assets, liabilities and cash flows. Further, ensure to classify your
      assets and liabilities between current and long-term pursuant to Article
      5-02 of Regulation S-X.

2.    Comment

      As noted in our prior comment no. 2, we would not object to your
      presenting "tiered" financial statements as supplemental information in
      addition to your consolidated financial statements if you believe they are
      useful and meaningful to investors. If you choose to present tiered
      information within your primary financial statements, it should
      immediately

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      follow the corresponding consolidated financial statement. For example, if
      you present a tiered balance sheet, it should immediately follow your
      consolidated balance sheet, preferably with the word "supplemental" in the
      title of the tiered financial statement. Other alternatives may be to
      present this information either in a footnote to your primary financial
      statements or in a separate statement following your primary financial
      statements as supplemental information. In addition, when "tiered"
      financial statements are presented, your disclosures should include an
      explanation of why the information is being presented, and if presented
      for selective financial statements (balance sheet only, for example), you
      should explain why. Finally, we would expect the company's audit report to
      include any such supplemental statement that you file.

      Management's Responses to Comments 1 and 2

      At the SEC's request, future filings will include consolidated balance
      sheets and statements of cash flows without segregating automotive
      solutions and financial services. Assets and liabilities will be
      classified between current and long-term pursuant to Article 5-02 of
      Regulation S-X. The company has decided not to present any supplemental
      financial statements at this time. If the company chooses to present
      supplemental financial statements in the future, it will be marked as
      supplemental and presented immediately after the primary financial
      statements.

Prior Comment no. 3

3.    Comment

      We note that you have recorded current and non-current deferred costs and
      license fees at September 30, 2004 and 2003. With respect to these
      deferred costs and license fees tell us the nature of the transactions
      that resulted in you recording these costs/fees, your policy for
      recognizing these costs as an expense, the authoritative literature that
      applies and if applicable, how these costs relate to your deferred
      revenue.

      Management's Response

      As a software vendor the company uses other software vendors' solutions in
      developing and delivering its own software solutions. The company
      typically purchases these software licenses in advance and in bulk to
      obtain a lower per unit cost than if purchased each time we sell a
      solution to a customer and utilize a third party license. The company
      capitalizes these actual costs paid to third parties as required by FASB
      Concept Statement No. 6. These costs represent a future benefit as the
      company licenses the software, the company controls our customers' access
      to these licenses and the transaction giving right to the company's
      control of this future benefit has already occurred (FASB Concept
      Statement No. 6, paragraph 26). The company's policy is to expense these
      costs over the implementation period in which software revenues are
      recorded.

      Deferred costs consist of set-up and training costs for which software
      revenues or hosting revenues have not yet been recognized. These costs are
      deferred as permitted by SAB 104, Topic 13A, Section 3f, Questions 3
      through 5. This guidance permits costs incurred in the acquisition of a
      customer contract that results in the deferral of revenues to be either
      expensed as incurred or accounted for in accordance with FTB 90-1
      paragraph 4 or SFAS 91

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      paragraph 5. This guidance states that costs that are directly related to
      the acquisition of a contract and that would not have been incurred but
      for the acquisition of that contract should be deferred and charged to
      expense in proportion to the revenue recognized. The company's policy is
      to expense these deferred costs over the contract period as revenues are
      recognized. In future filings the company will disclose this policy
      regarding deferred costs.

Prior Comment no. 4

4.    Comment

      We note that you consider your hardware installation service to be
      software related and subject to SOP 97-2. Supplementally, clarify why your
      hardware installation services are considered software related when your
      hardware element is not software related. Tell us how you have considered
      EITF 03-5 when making this determination. As part of your response,
      clarify whether your hardware installation services include any software
      installation services or whether you have a separate software installation
      service element contained in your arrangements.

      Management's Response

      The company's arrangements include a separate hardware installation fee
      and a separate software training fee. There is no software installation
      fee as the software is loaded on the hardware prior to shipment to the
      customer.

      EITF 03-5 states, "In an arrangement that includes software that is more
      than incidental to the products or services as a whole, software and
      software-related elements are included within the scope of SOP 97-2.
      Software-related elements include software products and services such as
      those listed on paragraph 9 of SOP 97-2 as well as any non-software
      deliverable(s) for which a software deliverable is essential to its
      functionality. For example, in an arrangement that includes software,
      computer hardware that will contain the software, and additional unrelated
      equipment, if the software is essential to the functionality of the
      hardware, the hardware would be considered software-related and,
      therefore, included within the scope of SOP 97-2. However, because the
      software is not essential to the functionality of the unrelated equipment,
      the equipment would not be considered software-related and would,
      therefore, be excluded from the scope of SOP 97-2."

      The company's software is not essential to the functionality of the
      hardware. Therefore the hardware is not considered software-related and
      not included within the scope of SOP 97-2. Similarly, because the
      company's software is not essential to the functionality of the hardware,
      the software is not essential to the functionality of the hardware
      installation services either. Therefore, the hardware installation
      services are not considered software-related under EITF 03-5 and are
      excluded from the scope of SOP 97-2.

      Because both paragraph 4 of SOP 97-2 and paragraph 4(a)ii of EITF 00-21
      require separation of leased hardware from the remainder of the
      arrangement using an entity's best estimate of fair value, the company has
      separated the leased hardware from the remainder of the arrangement and
      accounted for its direct financing leases of hardware in accordance with
      SFAS 13 as discussed in Appendix A. Unlike leased hardware, however, which
      is required

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      to be separated, hardware installation is not directly addressed by SFAS
      13. Accordingly, in these situations, paragraph 4 (a) iii of EITF 00-21
      requires that the separation criteria of EITF 00-21 be applied.
      Specifically paragraphs 8-10 of EITF 00-21 provide direction as to whether
      deliverables in an arrangement represent separate units of accounting.
      Paragraph 8 states that a vendor should evaluate all deliverables in an
      arrangement to determine whether they represent separate units of
      accounting. Paragraph 9 states, "in an arrangement with multiple
      deliverables, the delivered item(s) should be considered a separate unit
      of accounting if all of the following criteria are met."

             -    The delivered item(s) has value to the customer on a
                  standalone basis. That item(s) has value on a standalone basis
                  if it is sold separately by any vendor or the customer could
                  resell the delivered item(s) on a standalone basis.

             -    There is objective and reliable evidence of the fair value of
                  the undelivered item.

             -    If the arrangement includes a general right of return,
                  relative to the delivered item, delivery or performance of the
                  undelivered item(s) is considered probable and substantially
                  in the control of the vendor.

      The company does not have evidence of fair value of the software training
      services which are not delivered until after hardware installation
      services have commenced. Therefore the company does not meet the second
      criteria of paragraph 9 of EITF 00-21. Accordingly, the company combined
      the hardware installation services with the software and software training
      services for revenue recognition purposes.

      Paragraph 10 of EITF 00-21 states, "The arrangement consideration
      allocable to a delivered item(s) that does not qualify as a separate unit
      of accounting within the arrangement should be combined with the amount
      allocable to the other applicable undelivered item(s) within the
      arrangement. The appropriate recognition of revenue should then be
      determined for those combined deliverables as a single unit of accounting.

      Paragraph 12 of SOP 97-2 states that if VSOE does not exist for the
      allocation of revenue to the various elements of the arrangement, and if
      the only undelivered element is services that do not involve significant
      production, modification, or customization of software (for example,
      training or installation), the entire fee should be recognized over the
      period during which the services are expected to be performed.

      Accordingly, the company has recognized revenues for software (the
      delivered item), software training services and hardware installation
      services (the undelivered items) as a single unit of accounting, over the
      period in which hardware installation services and software training
      services are provided, in accordance with this guidance.

5.    Comment

      We note that your hardware element is accounted for as a leasing
      arrangement in accordance with SFAS 13. Tell us the classification of your
      leases pursuant to the criteria in paragraphs 6 through 8 of SFAS 13.
      Further, tell us how you considered the disclosure requirements of
      paragraph 23 of SFAS 13 for your lease arrangements. We may have
      additional comments based on your response.

      Management's Response

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      The company's leases are classified as direct financing leases. The leases
      are not classified as sales-type leases because the company is not
      considered a hardware dealer as it does not generate a dealer's profit on
      the sale of hardware. The company meets the criteria of paragraph 7d of
      SFAS 13 and both criteria of paragraph 8 of SFAS 13. In note 6 to the
      consolidated financial statements included in the company's annual report
      on Form 10-K for the year ended September 30, 2004, the company has
      disclosed future minimum lease payments (product financing receivables),
      unguaranteed residual values, unearned interest income and minimum lease
      payments (product financing receivables) due for the next five years. At
      September 30, 2004, initial direct costs were $3,141,000 and included in
      the line titled other of note 6 to the consolidated financial statement.

6.    Comment

      We note that you have established vendor specific objective evidence
      (VSOE) of fair value for the recurring component (software support and
      hardware maintenance) of your arrangements based on the renewal rate.
      Clarify whether your arrangements contain separate renewal rates for your
      software support and hardware maintenance or whether they contain one
      renewal rate for the recurring component. Supplementally clarify,

             -    Whether you have established VSOE of the fair value for such
                  service in accordance with paragraph 57 of SOP 97-2. If not,
                  tell us how your current method of establishing VSOE of fair
                  value for your software support is appropriate considering
                  that your recurring component contains a non-SOP 97-2
                  deliverable.

             -    How using the renewal rate to establish fair value of your
                  hardware maintenance service complies with SFAS 13. Tell us
                  how you apply the guidance in SFAS 13 to establish fair value
                  of your hardware maintenance element. Further, tell us whether
                  your hardware leasing arrangements include a separate fee for
                  maintenance services or whether maintenance services are
                  included in the total hardware consideration.

      Management's Response

      The company's arrangements contain separate renewal rates for hardware
      maintenance and software support. VSOE of fair value for software support
      has been determined consistent with the guidance of paragraph 57 of SOP
      97-2. The software support does not contain a non-software deliverable.
      The company's leasing arrangements also contain a separate fee for
      hardware maintenance. Under SFAS 13 the company is required to separate
      the maintenance element from the hardware lease based on a reasonable
      estimate of the fair value of the maintenance element. The company
      believes that the separately stated fee for hardware maintenance, as
      validated by renewals of its customers at those rates, provides a
      reasonable estimate of the fair value of the hardware maintenance element.

7.    Comment

      Your response indicates that you recognize revenue for your software