SecProbe.io

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Mail Stop 4-06

March 21, 2005

Gary C. Kaufman
Executive Vice President, Finance and Administration
and Chief Financial Officer
MICROS Systems, Inc.
7031 Columbia Gateway Drive
Columbia, Maryland 21046-2289

RE:		MICROS Systems, Inc. (file no. 000-09993)
		Form 10-K: For the Fiscal Year Ended June 30, 2004
		Form 10-Q: For the Quarterly Period Ended September 30,
2004
		Form 10-Q: For the Quarterly Period Ended December 31,
2004

Dear Mr. Kaufman,

We have reviewed the above referenced filings and have the
following
comments. Please note that we have limited our review to the
matters
addressed in the comments below.  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.

Form 10-K: For the Fiscal Year Ended June 30, 2004

		Management`s Discussion and Analysis of Financial
Condition
		and Results of Operations
		Results of Operations, page 21

1. Where you identify two or more sources of a material change, we
note the dollar amount that each source contributed to the change
is
not disclosed. Examples include, but are not limited to:

* The increase in 2004 hardware revenue due to sales of the
Workstation 4 offset by a decrease in the sale of PC Workstations;
* The increase in 2004 software revenue due to various rollout
programs and the sale of Datavantage`s suite of software products;
* The increase in service revenue due to increased support
revenues
and increased installation revenue from the continued expansion of
the MICROS customer base as well as the recurring support revenue
of
existing customers and the addition of professional services and
support provided by Datavantage; and
* This increase in selling, general and administrative expenses
due
to the acquisition of Datavantage, increases in salaries and
foreign
exchange.

Refer to SEC Release Nos. 33-8350 and 33-6850 and explain to us
what
consideration you gave to providing these disclosures throughout
your
MD&A.

2. We note that foreign currency exchange rates appear to have a
significant impact on your results of operations. What
consideration
did you give to providing sensitivity analyses that allow readers
to
understand the potential impact of rate changes on your results in
future periods?  It appears that presenting key historical amounts
on
a consistent foreign currency basis would also be useful
information.

		Financial Statements
		Note 1. Description of business and summary of
significant
accounting policies:
		Revenue Recognition, page 43

3. Supplementally, describe to us the material terms of your
agreement with HP to resell various hardware products.  In
addition,
tell us whether you recognize revenue on these products on a gross
or
net basis and support your accounting under EITF 99-19.

4. Your disclosures appear to indicate that installation services
requiring your "proprietary knowledge" are considered essential to
the functionality of your solutions. Supplementally, clarify for
us
whether you consider these services essential and support your
conclusion under paragraphs 70 and 71 of SOP 97-2.

5. If these proprietary installation services are deemed essential
to
the functionality of your solutions, explain to us how you
addressed
paragraph 64 of SOP 97-2 that requires contract accounting.
Currently, your disclosures do not appear to indicate that you are
using contract accounting and suggest that the hardware and
service
elements are accounted for separately from the license revenue
that
is deferred until the solution is ready to "go live."

6. Supplementally, clarify the nature of any undelivered software
contract elements that are subject to "appropriate deferral" if a
third party can install your software.

7. Explain to us how you considered the disclosure requirements of
paragraph 12 of APBO No. 22. In this regard, we note that you have
not disclosed how you determine whether pervasive evidence of an
arrangement exists, the fee is fixed or determinable and whether
collectibility is reasonably assured. In addition, you have not
disclosed how you determine VSOE for undelivered elements.

As appropriate, please respond to these comments within 10
business
days or tell us when you will provide us with a response.  Please
furnish a cover letter that keys your responses to our comments
and
provides any requested supplemental information.  Detailed cover
letters greatly facilitate our review.  Please understand that we
may
have additional comments after reviewing your responses to our
comments.

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 comments, 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.

You may contact Brent Watson, Staff Accountant, at (202) 824-5494,
Mark Kronforst, Senior Staff Accountant, at (202) 824-5341 or me
at
(202) 942-1800 if you have any questions regarding these comments.

							Very truly yours,

							Craig Wilson
							Senior Assistant Chief
Accountant
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MICROS Systems, Inc.
March 21, 2005
Page 4 of 4

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