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Mail Stop 4561         February 6, 2009  Dov Baharav Chief Executive Officer Amdocs Limited 1390 Timberlake Manor Parkway Chesterfield, Missouri 63017
Re: Amdocs Limited
 Form 20-F for the Fiscal Year Ended September 30, 2008
Filed December 8, 2008
 File No. 001-14840

Dear Mr. Baharav:

We have reviewed the above-referenced filing and have the following comments.
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 should revise your document 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
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 comments or any other aspect of our review.  Feel free to call us at the telephone numbers listed at the end of this letter.

Form 20-F for the Fiscal Year Ended September 30, 2008

General
1. Please provide us with the analysis that  supports your conclusion that you are a
foreign private issuer.  Refer to Rule 405 of Regulation C and Rule 3b-4 of the
Exchange Act.

Dov Baharav
AmdocsLimited
February 6, 2009 Page 2  Consolidated Financial Statements

 Notes to the Consolidated Financial Statements

 Note 3 – Acquisitions, page F-18

2. We note that in 2008 you recorded a $20 million adjustment to goodwill for a
valuation allowance that should have been  recorded in conne ction with your 2006
acquisition of Cramer.  Please explain your basis for recording this adjustment to
goodwill and refer to the authoritati ve guidance you relied upon when
determining your accounting.
 Note 5 – Accounts Receivable, Net, page F-22

3. Please explain your policy for unbille d receivables and tell us why you
reclassified certain amounts between s hort term unbilled receivables and long-
term unbilled receivables in your 2007 bala nce sheet.  As part of your response,
please tell us whether this reclassifica tion was related to a change in accounting
policy.  Refer to the authoritative guidance you relied upon when determining your accounting.
 Note 9 – Income Taxes, page F-25

4. Please tell us how you considered the disc losures required by paragraph 48(b) of
SFAS 109.   In this regard, we note that you have not quantified the portion of the valuation allowance for deferred tax assets  for which subsequently recognized tax
benefits will be allocated to reduce goodwill.

Note 19 – Segment Information and Sales to Significant Customers, page F-35

5. Please tell us what consideration you have given to proving a more detailed
breakout of “Customer experien ce systems” revenue.  In this regard, we note that
disclosures on page 23 appear to indicate that your services portfolio includes 4
types of services.  See paragraph 37 of SFAS 131.

* * * * * * *

Please respond to these comments 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 comments and provides any requested information.  Detailed co ver letters greatly faci litate our review.

Dov Baharav
AmdocsLimited February 6, 2009 Page 3  Please understand that we may have addi tional comments after reviewing any
amendment and your response to our comments.
 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 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 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 comments on your filing.
 You may contact David Edga r, Staff Accountant, at  (202) 551-3459, Christine
Davis, Assistant Chief Accountant, at ( 202) 551-3408, or me at (202) 551-3451 if you
have questions regarding the above comments.
        S i n c e r e l y ,           Mark Kronforst
Accounting Branch Chief