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September 16, 2011

VIA EDGAR

Mara L. Ransom

Assistant Director

United States Securities and Exchange Commission

Division of Corporation Finance

100 F Street N.E.

Washington, D.C. 20549-9303

    Re:

    Sysco Corporation

    Preliminary Proxy Statement on Schedule 14A

    Filed September 9, 2011

    File No. 001-06544

Dear Ms. Ransom:

     This letter sets forth the response of Sysco Corporation (the “Company”) to the comment of the
staff of the Division of Corporation Finance (the “Staff”) of the Securities and Exchange
Commission (the “Commission”) in a letter dated September 15, 2011, with respect to the above
referenced Preliminary Proxy Statement on Schedule 14A. For the convenience of the Staff, the
Staff’s comment is restated in italics prior to our response.

     Recommendation Regarding the Frequency with which Sysco Will Conduct Stockholder Advisory
Votes on Executive Compensation Item No. 3 on the Proxy Card, page 74

    1.

    We note your disclosure on page 74 regarding the advisory vote on the frequency
of the advisory vote on the compensation of your named executive officers. As drafted,
your disclosure in the third paragraph of this section and your resolution suggest that
shareholders must either vote for or against the advisory vote being held every year.
Please revise your disclosure and resolution to clarify that shareholders may vote that
the advisory vote on compensation should occur every one, two or three years, or may
abstain from voting. Please note that we do not object to the Board making a

September 16, 2011

Page 2

    recommendation, so long as all voting options available to the shareholders are clearly
stated. Refer to Section II.B.3 of the Securities Act Release No. 33-9178 (adopted
January 25, 2011).

     The Company respectfully acknowledges the Staff’s comment and will replace the disclosure
currently included in our Preliminary Proxy Statement under the heading “Recommendation Regarding
the Frequency with which Sysco will Conduct Stockholder Advisory Votes on Executive Compensation —
Item No. 3 on the Proxy Card” with the disclosure included in Attachment A, which has been
red-lined to show changes, in our Definitive Proxy Statement.

     On behalf of the Company, I acknowledge that (a) the Company is responsible for the adequacy
and accuracy of the disclosure in the filing, (b) 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 (c) 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.

     If you have any questions or comments regarding this letter, please contact me at (281)
584-1460 or B. Joseph Alley, Jr. of Arnall Golden Gregory LLP at (404) 873-8688.

    Sincerely,

Sysco Corporation

    By:

    Name:
    Emily B. Sperandio

    Title:
    Senior Director, Corporate Counsel —

Securities and Corporate Governance

cc: Christopher F. Chase

September 16, 2011

Page 3

Attachment A

RECOMMENDATION REGARDING THE FREQUENCY WITH WHICH SYSCO WILL CONDUCT

STOCKHOLDER ADVISORY VOTES ON EXECUTIVE COMPENSATION

ITEM NO. 3 ON THE PROXY CARD

     Pursuant to recent legislation and related SEC rules regarding the “Say on Pay” vote described
under Proxy Item #2, many public companies, including Sysco, are required to provide stockholders
this year with a non-binding vote regarding the frequency with which we will conduct future
stockholder advisory votes on executive compensation. Stockholders have a choice of recommending
that these Say on Pay votes be conducted once every one, two or three years, or to abstain .
We believe that a Say on Pay vote will be most effective as a communication tool for our
stockholders if it is conducted on an annual basis and, thus, recommend that you vote for Sysco to
conduct an annual stockholder advisory vote on executive compensation at our annual meetings.

     We believe that a Say on Pay vote provides a meaningful way for stockholders to communicate
with a company regarding their approval or disapproval of executive pay practices. However, the
vote is only effective if it is part of an ongoing regular dialogue between a company and its
stockholders. Because the nature of this type of stockholder feedback requires that votes cast will
only be “For” or “Against” our executive compensation in a general sense, our Board of Directors
and management will need to draw inferences from the vote as to what our stockholders most approve
and/or disapprove of with respect to our pay practices. Were the vote to occur only once every two
or three years, it may prove difficult to make use of the voting results to draw meaningful
conclusions. A high percentage of “Against” votes could rightly be interpreted to have been cast
with respect to various actions in different years. In the alternative, if the Say on Pay vote is
conducted annually, it may become a more powerful tool, as we will be able to trace not only
whether the vote gains 50% approval, but also fluctuations in our “For” and “Against” votes from
year to year.

     While we hope that the advisory Say on Pay vote will become a useful communication tool for
our stockholders, we believe that the vote will only be effective to the extent it fosters
continued and specific dialogue between our company and our stockholders. You may choose to
vote for the option of 1 year, 2 years or 3 years as the frequency for advisory votes on executive
compensation, or you may abstain. We recommend that you vote for the option of 1 year as
the frequency for advisory votes on executive compensation following advisory resolution on the
frequency of the executive compensation vote and invite you into continued discussion with us
regarding executive compensation generally.

     “Resolved, that Sysco’s stockholders recommend an annual stockholder vote on the compensation
paid to Sysco’s named executive officers, as disclosed in the annual proxy statement pursuant to
Item 402 of Regulation S-K, including the Compensation Discussion and Analysis, compensation tables
and narrative discussion.”

Required Vote

     The outcome of this advisory vote will be determined by a plurality of votes cast by the
holders of shares entitled to vote in the election. Accordingly, abstentions and broker non-votes
will not be relevant to the outcome. Stockholders may choose an annual, biennial or triennial
frequency, i.e., every year, every two years or every three years, or they may abstain. The
frequency option that receives the most votes will be deemed the option chosen by the advisory
vote.

The Board of Directors recommends a vote for ANNUAL stockholder advisory votes on executive compensation