SecProbe.io

November 29, 2010
 William J. Delaney Chief Executive Officer Sysco Corporation 1390 Enclave Parkway Houston, Texas  77077-2099

Re: Sysco Corporation
Form 10-K for the Fiscal Year Ended July 3, 2010 Filed August 31, 2010 Definitive Proxy Statement on Schedule 14A Filed September 29, 2010 Form 10-Q for the Fiscal Period Ended October 2, 2010 Filed November 9, 2010 File No. 001-06544

Dear Mr. Delaney:
 We have reviewed your response to our comment letter and have the following
comments.  You should comply with the comments in all future filings, as applicable.  Please confirm in writing that you will do so and also explain to us in sufficient detail for an
understanding of the disclosure  how you intend to comply by providing us with your proposed
revisions.  In some of our comments, we may as k you to provide us with information so we may
better understand your disclosure.
Please respond to this letter within te n business days by providing the requested
information or by advising us when you will provide the requested response.  If you do not believe our comments apply to your facts and circum stances, please tell us why in your response.
 After reviewing the information you provide in response to these comments, we may
have additional comments.

General

1. We note the acknowledgements made by your co unsel on your behalf at  the conclusion of
counsel’s letter to us dated N ovember 18, 2009.  Notwithstanding these
acknowledgements, we still require a le tter from you, on company letterhead and
executed by a duly authorized officer, acknowledging that:

• the company is responsible for the adequacy  and accuracy of the disclosure in the
filings;

William J. Delaney Sysco Corporation November 29, 2010 Page 2

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

• the company may not assert staff comme nts as a defense in any proceeding
initiated by the Commission or any person under the federal secu rities laws of the
United States.
 Form 10-Q for the Fiscal Period Ended October 2, 2010

2. In future filings, please delete the language  in the second and third sentences in which
you state that other unknown or immaterial  risks may also impair your business
operations.  All material risks should be described in your di sclosure.  If risks are not
deemed material, you should not reference them.
  We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing include s the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules requir e.  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.
Please contact Lilyanna L. Peyser, Attorney  Advisor, at (202) 551-3222 or me at (202)
551-3720 with any questions.

Sincerely,

H. Christopher Owings Assistant Director
 cc: B. Joseph Alley, Jr.  Via Facsimile