SecProbe.io

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Mail Stop 4-06

								September 19, 2005

John L. McGannon
President and Chief Executive Officer
Document Sciences Corporation
6339 Paseo del Lago
Carlsbad, CA 92009

	Re:	Document Sciences Corporation
      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. 000-20981

Dear Mr. McGannon:

      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

Item 9A.  Controls and Procedures, page 21

1. We note your disclosure that your Chief Executive Officer (who
also serves as your Chief Financial Officer), concluded that your
disclosure controls and procedures were effective as of December
31,
2004 to alert him of information required to be included in
periodic
filings.  Tell us how you considered Exchange Act Rule 13a-15(e)
concluding that your disclosure controls and procedures were also
effective to ensure that information required to be disclosed in
the
reports that you file or submit under the Exchange Act is
accumulated
and communicated to your management, including your chief
executive
officer and chief financial officer, to allow timely decisions
regarding required disclosure.

Note 1.  Organization and Summary of Significant Accounting
Policies,
Page F-7

Revenue Recognition, page F-9

2. Clarify to us your accounting for the sale of initial license
fees
and annual renewal license and support fees (i.e., "ALF sales").
Based on disclosure on page 6 of your June 30, 2005 Form 10-Q, it
appears that the Company`s policy changed from that disclosed in
your
December 31, 2004 Form 10-K.  For example, your disclosure in the
Form 10-K states that these revenues are recognized ratably over
the
contract period (as the Company does not separately sell the term
license and the related support and therefore cannot establish
VSOE
for each of these elements), while disclosure in the Form 10-Q
indicates that the Company uses the residual method for "all
license
models" and VSOE can be determined as contracts "specifically
state
the amount of initial and annual license fees due."  Tell us how
you
considered paragraph 14 of APB 20.  We may have further comments.

3. Explain to us how you identify the elements included in a
software
arrangement (i.e., software license, support, training,
consulting,
etc) and clarify how you establish VSOE for each of the elements
in a
multiple element arrangements.  Refer to paragraph 10 	of SOP 97-2
in
your response.

4. Clarify to us the Company`s accounting for contract losses on
fixed fee arrangements accounted for under the percentage of
completion method. Refer to SOP 81-1 and ARB 45 in your response.

******

      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 Craig Wilson, Senior Assistant Chief Accountant who supervised
this review, at (202) 551-3226 if you have questions regarding
comments on the financial statements and related matters, or me at
(202) 551-3730 with any other questions.

							Very truly yours,

							Kathleen Collins
      Accounting Branch Chief
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John L. McGannon
Document Sciences Corporation
September 19, 2005
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