SecProbe.io

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Mail Stop 4-06

								September 19, 2005

W. Michael Kipphut
Senior Vice President and Chief Financial Officer
Sykes Enterprises, Incorporated
400 N. Ashley Drive
Tampa, FL 33602

	Re:	Sykes Enterprises, Incorporated
      Form 10-K for Fiscal Year Ended December 31, 2004
Forms 10-Q for Fiscal Quarters Ended March 31, 2005
and June 30, 2005
      File No. 000-28274

Dear Mr. Kipphut:

      We have reviewed the above referenced filing and have the
following comments.  Please note that we have limited our review
to
the matters addressed in the comments below.  We may ask you to
provide us with supplemental information so we may better
understand
your disclosure.  Please be as detailed as necessary in your
explanation.  After reviewing this information, we may 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 Fiscal Year Ended December 31, 2004

Note 1.  Summary of Significant Accounting Policies, page 50

Recognition of Revenue, page 50

1. You disclose on page 32 of the filing that "changes in the
allocation of the sales price between deliverable elements might
impact the timing of revenue recognition."  Clarify this
statement.
Explain why changes in the allocation would occur and how changes
in
the allocation would effect the Company`s determination that the
sales price is fixed and determinable.  We may have further
comments.

2. You state in the filing that royalty revenue is recognized at
the
time royalties are earned.  Clarify this statement.  Quantify the
materiality of these revenues and tell us how the Company
determines
the general conditions for recognition of these revenues.  Also,
tell
us how the Company`s policy for recognition of these revenues
complies with the substance of the agreements.

3. You state in the filing that many of your contracts contain
penalty provisions for failure to meet minimum service levels and
other performance based contingencies.  Describe the terms of the
contracts that include these minimum service requirements. Clarify
the significance of these provisions and tell us how the Company
is
able to reasonably estimate these amounts.  Clarify whether
material
revisions to such estimates have been required in the past and
tell
us how you determined that the fees associated with these
contracts
are fixed and determinable given these contingencies.  Quantify
the
amount in deferred revenues relating to estimated holdbacks.  We
may
have further comments

Note 13.  Income Taxes, page 60

4. Clarify where you have accounted for the $2.9 million
contingent
income tax liability as of and for the year ended December 31,
2004.
In addition, tell us to which tax year(s) and to which audit(s)
this
liability relates.    Clarify how you determined that the result
of
these examinations is not expected to have a material effect on
the
Company`s operations.  We may have further comments

5. You disclose on page 25 of the filing that "certain specific
tax
contingency reserves" were reversed during FY 2004.  Quantify the
amount of reserves that were reversed and clarify the
circumstances
surrounding the reversal. We may have further comments.

Note17.  Commitments and Contingencies, page 67

6. You disclose on page 68 in the filing, that the Company
believes
it is reasonably probable that a liability may have been incurred
before December 31, 2004 and that management estimates this amount
to
be immaterial.  Clarify for us the nature of the liability and
tell
us whether this is in any way associated with the contingent tax
liability discussed in Note 13.  In addition, tell us how you
considered the requirements of paragraph 10 of SFAS 5 to disclose
the
specific nature of the liability and the estimate of the possible
loss (or range of loss).

Form 10-Q for the Quarter Ended June 30, 2005

Item 4.  Controls and Procedures, page 34

7. We note your statement that your Chief Executive Officer and
your
Chief Financial Officer have concluded that your disclosure
controls
and procedures were "generally effective" to ensure that
information
required to be disclosed by the Company in the reports it files or
submits under the Securities and Exchange Act of 1934 is recorded,
processed, summarized and reported within the time period
specified
in the applicable rules and forms. It is not clear if your
certifying
officers have reached a conclusion that your disclosure controls
and
procedures are effective. Your disclosures should state, in clear
and
unqualified language, the conclusions reached by your chief
executive
officer and your chief financial officer on the effectiveness of
your
disclosure controls and procedures. Please tell us what
consideration
you have given to this guidance.  See Item 307 of Regulation S-K
and
Release 33-8238.

******

      As appropriate, please amend your filing and respond to
these
comments within 10 business days or tell us when you will provide
us
with a response.  You may wish to provide us with marked copies of
any amendment to expedite our review.  Please furnish a cover
letter
with any amendment that keys your responses to our comments and
provides any requested information.  Detailed cover letters
greatly
facilitate our review.  Please understand that we may have
additional
comments after reviewing any amendment and 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 Megan Akst, Staff Accountant, at (202) 551-3407 or
me
at (202) 551-3499 if you have questions regarding comments on the
financial statements and related matters.

							Very truly yours,

							Kathleen Collins
      Accounting Branch Chief
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W. Michael Kipphut
Sykes Enterprises, Incorporated
September 19, 2005
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