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  MICROS
  Systems, Inc

  7031
  Columbia Gateway Drive

  Columbia,
  MD 21046-2289

April 15, 2005

UNITED STATES SECURITIES AND EXCHANGE COMMISSION

Division
of Corporation Finance

450
Fifth Street, N.W.

Washington,
D.C.  20549

Attn:
Craig Wilson, Senior Assistant Chief Accountant, Brent Watson, Staff Accountant

Re:          MICROS Systems, Inc. (File No.
000-09993)

Form 10-K for the fiscal year ended June 30, 2004

Form 10-Q for the fiscal quarter ended September 30,
2004

Form 10-Q for the fiscal quarter ended December 31,
2004

Dear
Mr. Wilson, and Mr. Watson:

On March 21, 2005, I received your letter dated March 21,
2005 (the “Letter”) from the staff of the Securities and Exchange Commission
(the “Staff”) with respect to MICROS Systems, Inc.’s (the “Company”) Form 10-K for
the fiscal year ended June 30, 2004 (the “2004 10-K”) and Forms 10-Q for
the quarterly periods ended September 30 and December 31, 2004.  In response to the comments provided to me in
this Letter, I am providing a detailed explanation as well as any supplemental
information requested.  For your
convenience, we have repeated each of the Staff’s comments in bold prior to our
responses, and we have included in our responses, as exhibits, various
referenced pages from our 2004 10-K.

Management’s Discussion and
Analysis of Financial Condition and 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 sale
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, increase in
salaries and foreign exchange.

Refer to SEC Release Nos. 33-8350 and 33-6835 and explain to us what
consideration you gave to providing these disclosures throughout your MD&A.

Comment 1 Response:

Our reporting objective in our Management’s Discussion and
Analysis of Financial Condition and Results of Operations (“MD&A”) is to
provide readers information in a “clear and straightforward manner” that
enables “investors an opportunity to look at the company through the eyes of
management.”  We believe this reporting
objective is met by providing the context in which information should be
analyzed, and by providing information in order to help an investor ascertain
whether or not past performance is indicative of future performance.  We are relying on the interpretive guidance
provided in SEC Release Nos. 33-8530 and 33-6835 in making our disclosures.

In our filings, we disclosed in MD&A the reasons for
the changes between two or more sources to the extent, we believe, it will
provide readers an understanding of the business as a whole.  After careful consideration of each
disclosure, we did not include dollar amounts in instances when providing that
information would overly complicate a reader’s understanding

of the business as a whole, provide a level of detail that would be overly
burdensome or unnecessarily provide to our competitors a competitive
advantage.  In other instances, in
accordance with Instruction 4 of Item 303(a), we did not include dollar amounts
where it would create repetition of line items or where the figures were
readily computed from the financial statements or supporting tables.

However, we note the Staff’s comments and will address
these by further expanding our disclosures.
Where appropriate, we will include additional tables and narratively
expand upon the specific details of each material change presented.

The examples provided to us in your comment are illustrated
and described further below in order to describe our consideration of these
specific disclosures as well as other disclosures not presented herein.

The increase in 2004 hardware revenue due to
sale of the Workstation 4 offset by a decrease in the sale of PC Workstation

In our discussion of year-over-year changes in revenue in
our MD&A, we breakdown changes in revenue from 2003 to 2004 by sales mix
(hardware, software and service), which management believes is useful to
investors in understanding our business as a whole (see 10-K Ex. 5 &
7).  We do not quantify the drivers
within individual categories beyond this level of detail, a practice which is
in line with the disclosure practice in our industry.  Further, management does not believe that
this information is necessary to an understanding of the changes that are
described in narrative form in our disclosure and that, pursuant to
Interpretive Release No. 33-6835, Section III.D., first paragraph,
quantifying the drivers behind the changes in revenue by sales mix is not
required.

Management believes that the disclosure on page 22 (see
10-K Ex. 5) analyzing the changes in hardware revenue meets the requirements of
Interpretive Release No. 33-6835 because we identify the increase of
approximately $14,627,000 in hardware revenue as:

•                  primarily due to the sale of Workstation 4, which was released in the fourth
quarter of 2003 and, therefore, had a significantly greater impact on 2004
results than on 2003 results

•                  and offset by a decrease
in the sale of PC Workstations, which constitute an older technology platform
being replaced by Workstation 4.

With respect to the increase in Workstation 4 sales, we
describe, on page 5 of our 10-K, the product and its recent addition to our
suite of products (see 10-K Ex. 2). We believe this information provides the
basis for understanding our overall businesses and product offering.

Supplementally, we do not consider customer specific or
product level specific dollar amount information helpful in meeting our
reporting objectives for the following reasons:

•                  No customer is considered a material customer requiring disclosure — No
customer accounts for more than 10% of consolidated revenues (Regulation S-K;
229.100; Item 101(c)(iiv)), and the loss of any current customer would not
significantly impact our results;

•                  Our ability to provide detailed customer information publicly is usually
contractually limited by the agreement with the customer; and

•                  We do not consider dollar amount detail, by customer, information that is
comparable with our competitors public disclosures including but not limited to
NCR Corporation (Symbol: NCR), International Business Machines (Symbol: IBM),
Radiant Systems (Symbol: RADS), and Par Technologies (Symbol: PTS).

One example of how a customer may contractually limit our
ability to disclose its purchasing information is as follows:

•                  The XYZ Corporation is protective of the use of its brand name. When we
sell our product to the XYZ Corporation, XYZ stipulates in the contract that we
must separately negotiate permission to use its name associated with the
purchase.  In this example, the XYZ
Corporation would require that we pay a fee of $1,000,000 if we disclose that
they are our customer; providing this disclosure and paying this fee is not in
the best interest of our shareholders.

2

The increase in 2004 software revenue due to
various rollout programs and the sale of Datavantage’s suite of software
products

Management believes that the disclosure on page 22 (see
10-K Ex. 5) analyzing the changes in software revenue meets the requirements of
Interpretive Release No. 33-6835 because we identify the increase of
approximately $14.9 in software revenue as:

•                  Primarily due to an increase in volume purchases from a number of
customers (i.e. rollout programs)

•                  Software product offerings by Datavantage, which we acquired effective May
1, 2003 and, therefore, had a significantly greater impact on 2004 results than
on 2003 results.

Our disclosure does not provide specifics of those multiple
site customer sales (rollout programs) as we believe it would affect future
prices obtained for the same product.
Each major sale is a set of specific facts and circumstances; these
include software requirements, development needs, hardware configuration,
customer commitments, and geographic issues.
Accordingly, each contract is negotiated separately with each customer.  We do not want future negotiations with
potential customers to be adversely impacted by disclosing customer pricing
details. Our sales strategy is to negotiate our prices from a set of list
prices, and we do not want potential future customers basing their pricing
decision on another customer’s price who may have entirely different facts and
circumstances. Depending on the customers situation,
we offer certain incentives from our list price, and not from another customer’s
price.

In addition, some of our multiple site customers require
that their purchasing information not be disclosed unless negotiated as part of
the agreement (see XYZ Corporation example above).  We do, on occasion, obtain our customer’s
permission to disclose their purchase information, and have detailed those
customers in Part 1, Item 1 — “Business” in our Form 10-K.  Also, when we obtain a customer’s permission
to disclose their purchase publicly, we issue, separately, an independent press
release. However, we still do not include pricing information for the reasons
already provided.

Lastly, we do not provide the specific details of the
increases from Datavantage, our newly acquired subsidiary, because we felt the
disclosures made in other parts of the filing related to the acquisition of
Datavantage was sufficient, specifically pages 3, 6 and page 18 of our 2004
Form 10-K (see 10-K Ex. 1, Ex. 3, & Ex. 4).

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

Management believes that the disclosure on page 22 (see
10-K Ex. 5) analyzing the changes in service revenue meets the requirements of
Interpretive Release No. 33-6835 because we identify the increase of
approximately $52.1 million in service revenue as:

•                  mainly due to increased
support and installation revenue from new customers;

•                  along with support revenue
from existing customers

The primary reason our service revenue increases as our
customer base grows is because our customers prefer a “one-stop-shop” for all
their IT needs. We do, however, have customers and prospects who
prefer to support the product themselves. Since each sale is a set of specific
facts and circumstances, and those facts and circumstances are negotiated
separately with each and every customer, identifying every variable associated
with our service revenue is not meaningful.
Competition, level of a customer’s Information Technology (“IT”)
expertise, a customer’s financial constraints, and various other market and
customer specific factors impact our customers purchasing behavior toward
service and support.

However, we note the Staff’s comment and will address this
by further expanding our disclosures related to the recurring nature of our
service maintenance revenue.  Where
appropriate, we will include additional tables and narratively expand upon the
specific details of each material change presented.

This increase in selling, general and
administrative expenses due to the acquisition of Datavantage, increase in
salaries and foreign exchange

On page 23 of our 2004 Form 10-K (see 10-K Ex. 6), we
describe the drivers behind the $22.6 million increase in selling, general and
administrative expenses as:

•                  primarily due to $13.0 million
in expenses related to the acquisition of Datavantage which had a significantly
greater impact on 2004 results than on 2003 results;

3

•                  salary increases and related
salary expenses (primarily from annual merit increases and the rising cost of
employee related expenses (e.g. healthcare and 401(k) match);

•                  the effects of foreign
currency related changes; and

•                  $1.3 million of
expenses related to compliance with our obligations under Section 404 of
the Sarbanes-Oxley Act.

In future filings, we intend to clarify the components of
salary increases and related salary expenses in order to assist a reader in
assessing the impact of such items on our operations as shown in the following
example:

Selling, general and administrative expenses increase $22.6
million, or 17.1%, in fiscal year 2004 compared to fiscal year 2003.
Approximately $13.0 million of this increase is the result of the acquisition
of Datavantage. We acquired Datavantage on May 1, 2003. As a result, in fiscal
year 2003, we recorded only two months of SG&A expenses related to
Datavantage compared to twelve months expense recorded in fiscal year 2004. In
addition, we incurred $1.3 million of additional expenses related to compliance
with our obligations under Section 404 of the Sarbanes-Oxley act. The
remaining $8.3 million increase is primarily a result of salary costs due to
annual merit increases and the rising cost of employee related expenses (i.e.
Healthcare, 401(k) match), which coupled to a lesser extent with foreign
currency related changes have contributed to the overall increase in SG&A
expenses, comparatively.

4

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
period? It appears that presenting key historical amounts on a consistent
foreign currency basis would also be useful information.

Comment 2 Response:

Historically, changes in foreign currency exchange rates
have not been material to our business or our results of operations, and
primarily impact our International reporting segment. We have reviewed Item 305
of Regulation S-K and, because management believes that our exposure to foreign
currency exchange rate risk has historically not been material, we have not
presented quantitative information or sensitivity analyses with respect to
foreign currency exchange rate risk.

We believe, however, that disclosing the % of reported
revenue by functional currency as well as month end exchange rates will provide
investors a better understanding of foreign currencies impact, comparatively,
on our results. Prospectively, we intend to include as an example the
disclosure below starting with our June 2005 annual report on Form 10-K.
An example of our proposed prospective disclosure is as follows:

The Company’s revenue for fiscal 2004 was transacted in
approximately twenty-three currencies, while in fiscal years 2003 and 2004, the Company’s revenue was transacted in approximately
twenty-four.  The relative mix over the
past three years was as follows:

  Year Ended June 30,

  % of Reported Revenues

  Month End
  Exchange Rates (*)

  Revenues by
  currency (1)

  2004

  2003

  2002

  2004

  2003

  2002

  United
  States Dollar

  58

  %

  56

  %

  58

  %

  1.00

  1.00

  1.00

  European
  Euro

  24

  %

  27

  %

  24

  %

  1.1515

  0.9914

  0.8503

  British
  Pound