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Mail Stop 4561         March 26, 2008    Mr. Dov Baharav  Chief Executive Officer  Amdocs Limited  1390 Timberlake Manor Parkway  Chesterfield, MO 63017
Re: Amdocs Limited
 Form 20-F for the Fiscal Year Ended September 30, 2007
Filed December 3, 2007
 File no. 1-14840

Dear Mr. Baharav:

We have reviewed the above referenced filing and have the following comment.
Please note that we have limited our review to only your financial statements and related disclosures and do not intend to expand our review to other portions of your document.  If indicated, we think you s hould revise your document in re sponse to this comment.  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 our
comment, we may ask you to provide us with  supplemental information so we may better
understand your disclosure.  After reviewing th is information, we may raise additional
comments.
 Please understand that the purpose of our re view 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 comment or any other aspect of our review.  Feel free to call us at the telephone numbers listed at the end of this letter.

Mr. Dov Baharav
Amdocs Limited
March 26, 2008  Page 2  Form 20-F Filed for the Period Ended September 30, 2007

 Item 18. Financial Statements

Notes to the Consolidated Financial Statements

Note 3 Acquisitions, pages F-18 to F-23
1. We note your references to the use of independent valuations to value the
intangible assets acquired in the acquisitions disclosed in Note 3.  Please note that
when you refer to an independent valua tion specialist you need  to disclose the
name of the expert and, if your annual repor t is incorporated by reference into a
Securities Act registration statement, include  the expert’s consent.  Refer to Rule
436(b) of Regulation C and file the consent, if necessary.

* * * * * * *

Please respond to this comment within 10 business days or tell us when you will
provide us with a response.  Please submit all correspondence and supplemental materials
on EDGAR as required by Rule 101 of Regulation S-T.  If you amend your filing(s), you may wish to provide us with marked copies of any amendment to expedite our review.  Please furnish a cover letter that keys your response to our comment and provides any
requested information.  Detailed cover letters greatly facilitate our review.  Please
understand that we may have additional comm ents after reviewing any amendment and
your response to our comment.

We urge all persons who are responsible for the accuracy and adequacy of the
disclosure in the filing to be certain that the filing includes all in formation required under
the Securities Exchange Act of 1934 and th at they have provided all information
investors require for an informed invest ment decision.  Since the company and its
management are in possession of all facts re lating 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 comment, 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

Mr. Dov Baharav
Amdocs Limited  March 26, 2008  Page 3
• 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 advise d that the Division of Enfo rcement has access to all
information you provide to the staff of the Divi sion of Corporation Fi nance in our review
of your filing or in response to our comment on your filing.
 You may contact Marc Thomas, Staff A ccountant, at (202) 551- 3452 or me at
(202) 551- 3451 if you have any questions  regarding the above comment.
        S i n c e r e l y ,           Mark Kronforst
Accounting Branch Chief