SecProbe.io

January 26, 2011
 Mr. Thomas G. O’Brien Treasurer and Secretary  Amdocs Limited 1390 Timberlake Manor Parkway Chesterfield, Missouri 63017
Re: Amdocs Limited
 Form 20-F for the Fiscal Year Ended September 30, 2010
Filed December 7, 2010 Amendment No. 1 to Form 20-F for the Fiscal Year Ended
September 30, 2010
  Filed December 9, 2010
File No. 001-14840

Dear Mr. O’Brien:
 We have reviewed your filings and have th e following comments.  Please note that we
have limited our review to only your financial statements and related disclosures.  In some of our
comments, we may ask you to provide us with  information so we may better understand your
disclosure.
 Please respond to this letter within ten business days by amending your filing, by
providing the requested information, or by advi sing us when you will provide the requested
response.  If you do not believe our comments apply to your fact s and circumstances or do not
believe an amendment is appropriate, pl ease tell us why in your response.
 After reviewing any amendment to your filing and the information you provide in
response to these comments, we ma y have additional comments.
            Form 20-F for the Fiscal Year Ended September 30, 2010

 Item 5.  Operating and Financial Review and Prospects

 1. We note the disclosure in  your Form 6-K filed on N ovember 4, 2010 regarding the
suspension of a portion of Clearwire’s impl ementation program. We further note that you
anticipate that this suspension will put “press ure on [y]our profitabil ity.” Please tell us
how you considered disclosing whether this even t is reasonably likely to have a material
unfavorable impact on future revenues, gr oss margin or operating income and how you
considered including a discussion of this ev ent in your Form 20-F.  Refer to Section
III.B.3 of Release No. 33-8350 for additional guidance.

 Mr. Thomas G. O’Brien Amdocs Limited January 26, 2011 Page 2
 Item 8. Financial Information

 Financial Statements

 Note 2 – Summary of Significant Accounting Policies

 Revenue Recognition, page F-11

 2. We note that you allocate revenue in your ar rangements with multiple deliverables based
upon vendor-specific objective evidence (“VSOE”) .  We further note your disclosure on
page 39 that VSOE is based on normal prici ng and discounting practi ces when elements
are sold separately.  Please  describe, in detail, your methodology and assumptions for
establishing VSOE of fair va lue.  In your response, as  it relates to on-going support
services and maintenance, describe the proce ss used to evaluate the various factors that
affect how you establish VSOE of fair value.  For instance, does the price charged for the
on-going support services and maintenance vary  from customer to customer?  If so,
please explain how you determined that you can  reasonably estimate the fair value of on-
going support services a nd maintenance.  In this regard, if your agreements include stated
future renewal rates, tell us what percenta ge of your customers actually renew at these
stated rates and provide the range of typical renewal rates that are stated in your
contracts.  If stated future renewal rates are not included in  your agreemen ts, tell us the
percentage range allowed for your pricing of  on-going support servic es and maintenance
that you consider to be representative of VSOE.
3. We note your discussion on pages F-13 and F- 15 regarding the early  adoption of the
October 2009 FASB guidance related to revenue arrangements with multiple
deliverables.  Please address the following:
 Describe the significant f actors, inputs, assumptions, and methods used to
determine third-party evidence of sell ing price (“TPE”) for the significant
deliverables in your multiple deliverab le arrangements. Please update your
disclosure in future filings accord ingly. Refer to ASC 605-25-50-2(e).

 Tell us whether you typically determine fair value of the elements in your
arrangements using VSOE, TPE or estimated selling price (“ESP”).

 We note that your policy for determining ESP references “pricing practices” and
“margin objectives.”  Please clarify whet her you typically apply a gross profit
margin to your estimated costs in order to determine ESP and how gross profit margins and costs are determined.  Refer to ASC 605-25-55-44.

 Mr. Thomas G. O’Brien Amdocs Limited January 26, 2011 Page 3
 Note 9 – Goodwill and Intangible Assets, Net, page F-24

 4. We note your disclosure on page F-25 regardi ng your purchased intangible assets.  Please
tell us how you considered disclosing the we ighted-average amortiz ation period in total
and by major intangible asset class as required by ASC 350-30-50-1.
 Note 11 – Income Taxes, page F-26

 5. Please tell us how you considered separate ly disclosing income before income tax
expense for domestic and foreign operations. Refer to Rule 4-08(h) of Regulation S-X.

Amendment No. 1 to Form 20-F for the Fiscal Year Ended September 30, 2010

 6. We note that you did not file the certifica tions required under Ru les 13a-14(a) and 15d-
14(a) of the Exchange Act w ith your amendment to the Form 20-F for the fiscal year
ended September 30, 2010.  Please tell us how you considered including the required
certifications in your amended Form 20-F and the reason for omitting such certifications.

We urge all persons who are responsible for th e accuracy and adequacy of the disclosure
in the filing to be certain that the filing include s the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules requir e.  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 responding to our comments, please provi de a written statement from the company
acknowledging that:
 the company is responsible for the adequacy an d accuracy of the disclo sure 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 federa l securities laws of  the United States.

 Mr. Thomas G. O’Brien Amdocs Limited January 26, 2011 Page 4
 You may contact Jaime John at (202) 551-3446 if you have questions regarding
comments on the financial statements and rela ted matters.  Please contact me at (202)
551-3406 with any other questions.

Sincerely,
   /s/ Patrick Gilmore
Patrick Gilmore Accounting Branch Chief