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CORRESP
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      Response Letter

    ARNALL
      GOLDEN GREGORY LLP

    171
      17TH
      STREET NW

    SUITE
      2100

    ATLANTA,
      GEORGIA 30363-1031

    Direct
      phone: 404.873.8688

    Direct
      fax: 404.873.8689

    E-mail:
      joseph.alley@agg.com

    www.agg.com

    May
      18,
      2007

    VIA
      EDGAR

    Mr.
      Adam
      Phippen

    Division
      of Corporation Finance

    U.S.
      Securities and Exchange Commission

    100
      F
      Street, NE

    Washington,
      D.C. 20549-0405

    Mail
      Stop
      3561

              Re:

              SYSCO
                Corporation

              Item
                4.02 Form 8-K

              Filed
                May 7, 2007

              File
                No. 1-6544

    Dear
      Mr.
      Phippen:

    On
      behalf
      of SYSCO Corporation (“SYSCO” or the “Company”), we transmit for filing SYSCO’s
      response to the staff’s letter of comment dated May 8, 2007. For your
      convenience, the comment contained in that letter is reprinted below in italics.

    SYSCO’s
      response is as follows:

    Form
      8-K filed May 7, 2007

    1.     In
      light of the restatements please confirm to us that your officers’ reconsidered
      their conclusions regarding the effectiveness of disclosure controls and
      procedures for the quarterly periods ended September 30, 2006 and December
      30,
      2006. In future filings, when you amend your periodic reports to file restated
      financial statements, describe the effect of the restatement on the officers’
conclusions regarding the effectiveness of disclosure controls and procedures.
      If the officers’ conclude that disclosure controls and procedures were
      effective, despite restatement, describe the basis for the officers’
conclusions. See Item 307 of Regulation S-K.

    Response:

    On
      behalf
      of SYSCO, we confirm that SYSCO’s officers reconsidered their conclusions
      regarding the effectiveness of disclosure controls and procedures for the
      quarterly periods ended September 30, 2006 and December 30, 2006 in light of,
      and giving due consideration to, the restatements and the reasons therefor,
      and
      concluded that SYSCO’s disclosure controls and procedures were effective as of
      those dates at the reasonable assurance level, despite the restatements. We
      also
      confirm that, in future filings, when SYSCO amends its periodic reports to
      file
      restated financial statements, it will describe the effect of the restatement
      on
      the officers’ conclusions that disclosure controls and procedures were
      effective, and if the officers conclude that disclosure controls and procedures
      were effective despite the restatement, it will describe the basis for the
      officers’ conclusions.

    Mr.
      Adam
      Phippen

    May
      18,
      2007

    Page
      2

    SYSCO
      acknowledges that:

            ·

              it
                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;

            ·

              it
                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; and

            ·

              the
                Division of Enforcement has access to all information provided by
                SYSCO to
                the staff in its review of SYSCO’s filing or in response to staff comments
                on SYSCO’s filing.

    If
      you
      have any questions, please do not hesitate to contact me at (404)
      873-8688.

              Very
                truly yours,

              ARNALL
                GOLDEN GREGORY LLP

             /s/
              B. Joseph Alley, Jr.

              B.
                Joseph Alley, Jr.

              cc:

              William
                Thompson, Branch Chief, Division of Corporation Finance

              John
                K. Stubblefield, SYSCO Corporation

              Michael
                C. Nichols, SYSCO Corporation