SecProbe.io

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                                     AMDOCS

                              March 3, 2005

VIA EDGAR
---------

SECURITIES AND EXCHANGE COMMISSION
Division of Corporation Finance
Judiciary Plaza
450 Fifth Street, N.W.
Washington, DC 20549
Attention: Jeffrey Werbitt

      Re:   AMDOCS LIMITED
            Post-Effective Amendment No. 5 to Form F-3
            filed on February 23, 2005 (File No. 333-114344)
            ------------------------------------------------

Ladies and Gentlemen:

      On behalf of Amdocs Limited (the "Company"), please find below an
acknowledgment of the Company as requested by the staff (the "Staff") of the
Securities and Exchange Commission (the "Commission") in the letter dated March
2, 2005, from Ms. Barbara C. Jacobs, Assistant Director, Division of Corporation
Finance of the Commission. The comment letter relates to the above-referenced
Post-Effective Amendment (the "Amendment") to Registration Statement on Form F-3
(the "Form F-3") filed by the Company with the Commission on February 23, 2005.

      In the comment letter, the Staff requested that the Company acknowledge
certain matters with respect to the Amendment filing. Specifically, the Staff
provided the following comment:

              We urge all persons who are responsible for the accuracy and
      adequacy of the disclosure in the filings 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.

              Please furnish a letter acknowledging that:

                o should the Commission or the staff, acting pursuant to
                  delegated authority, declare the filing effective, it does not
                  foreclose the Commission from taking any action with respect
                  to the filing;

                o the action of the Commission or the staff, acting pursuant to
                  delegated authority, in declaring the filing effective, does
                  not relieve the company from its full responsibility for the
                  adequacy and accuracy of the disclosure in the filing; and

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                o the company may not assert this action 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 connection with our review of your filing or in
       response to our comments on your filing.

       By this letter, the Company hereby acknowledges that, should the
Commission or the Staff, acting pursuant to delegated authority, declare the
Amendment effective, it does not foreclose the Commission from taking any action
with respect to the Amendment. The Company further acknowledges to the
Commission that the action of the Commission or the Staff, acting pursuant to
delegated authority, in declaring the Amendment effective, does not relieve the
Company from its full responsibility for the adequacy and accuracy of the
disclosure in the Amendment. The Company acknowledges that it may not assert
this action as a defense in any proceeding initiated by the Commission or any
person under the federal securities laws of the United States, and that the
Division of Enforcement has access to all information provided to the Staff of
the Division of Corporation Finance in connection with the review of the
Amendment or in response to Staff comments on the Amendment.

            [THE REMAINDER OF THIS PAGE IS INTENTIONALLY LEFT BLANK]

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       Please do not hesitate to contact the undersigned at 314-212-8383 with
any questions regarding this response letter or the above acknowledgement.

                                             Very truly yours,

                                             /s/ Thomas G. O'Brien
                                             ---------------------------
                                             Thomas G. O'Brien
                                             Secretary and Treasurer

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