SecProbe.io

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                                                                      WilmerHale

                                                                Robert A. Schwed
                                                              +1 212 937 7276(t)
                                                              +1 212 230 8888(f)
                                                    robert.schwed@wilmerhale.com

July 26, 2006

Via EDGAR
---------

Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, DC  20549
Attention: Marc Thomas

Re:      AMDOCS LIMITED
         Form 20-F for Fiscal Year Ended September 30, 2005
         Filed December 28, 2005
         Form 6-K filed April 27, 2006
         Form 6-K filed May 17, 2006
         File No. 001-14840
         ------------------

Ladies and Gentlemen:

On behalf of our client Amdocs Limited (the "Company"), we are submitting the
following responses of the Company to a comment of the staff (the "Staff") of
the Securities and Exchange Commission (the "Commission") set forth in a letter
dated July 18, 2006, from Mr. Brad Skinner, Accounting Branch Chief of the
Commission. The comment letter relates to the Company's Annual Report on Form
20-F for the fiscal year ended September 30, 2005 filed December 28, 2005 (the
"Form 20-F"), the Company's Report of Foreign Private Issuer on Form 6-K
furnished April 27, 2006 (the "April Form 6-K") and the Company's Report of
Foreign Private Issuer on Form 6-K furnished May 17, 2006 (the "May Form 6-K").
As Jason Kropp of this firm discussed with Mr. Thomas, we believe that the
references in the Staff's letter to the Form 20-F and the May Form 6-K were in
error and that the Staff intended to refer to the Company's Report of Foreign
Private Issuer on Form 6-K furnished January 19, 2006 (the "January Form 6-K").

For convenient reference, we have included below the Staff's comment set forth
in the comment letter. The response is based on information provided to us by
representatives of the Company.

Please note that, on July 20, 2006, after receiving the Staff's letter, the
Company furnished a Report of Foreign Private Issuer on Form 6-K (the "July Form
6-K"), to which it attached as Exhibit 99.1 a press release (the "Earnings
Release") announcing the Company's financial results for the fiscal quarter
ended June 30, 2006. As described below, the Company took into consideration the
Staff's most recent comments in finalizing the Earnings Release and the July
Form 6-K, and the Company believes that it has addressed the Staff's comments in
the Earnings Release and the July Form 6-K. For convenient reference, we have
attached the Earnings Release as Exhibit A.

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                                                                      WilmerHale
Securities and Exchange Commission
July 26, 2006
Page 2

The Company carefully considered the desirability and appropriateness of
amending one or more of its past Reports of Foreign Private Issuer on Form 6-K
in order to reflect the "revised practices" described herein with respect to the
presentation of a non-GAAP operating statement. The Company continues to believe
that any such amendments would, on the whole, be more confusing than useful to
investors and others. It has been several months since the January Form 6-K and
April Form 6-K were furnished, and only days since the July Form 6-K, and
management believes it is highly unlikely that analysts, individual investors
and others would alter or reconsider their evaluation of the Company or an
investment in the Company's ordinary shares as a result of an amendment of past
filings to the effect described herein.

Management agrees that the Company's revised non-GAAP practices will improve
disclosures for investors in the future, but believes retrospective application
of those practices would not disclose any meaningful differences and may confuse
many investors who would assume that the amendments were made to disclose
significant adverse changes. The Company therefore respectfully submits that the
goal of improved disclosure regarding non-GAAP data will be served best by
continuing to implement the revised practices in all future filings, as it has
done in the July Form 6-K. In light of this, and because the Company continues
to believe that the amendments to past filings that would be required to address
the Staff's comment relate to matters that are not individually or in the
aggregate material to investors, the Company has not amended the January Form
6-K or the April Form 6-K.

Accordingly, and as it believes it has done with the July Form 6-K, the Company
requests that the Staff permit the Company to address the Staff's comment in
future filings under the Securities Exchange Act of 1934, as amended.

Form 6-K filed April 27, 2006
-----------------------------

1.     We have reviewed your response to your comment number 9 from our letter
       dated April 20, 2006 concerning the non-GAAP operating statement columnar
       format. We continue to have the concerns previously expressed over how
       investors might view that information due to the format in which it has
       been presented. As noted in our prior comment, we believe the non-GAAP
       operating statement columnar format may create the unwarranted impression
       to investors that the non-GAAP operating statement has been prepared
       under a comprehensive set of accounting rules or principles while also
       conveying undue prominence to a statement based on non-GAAP measures.
       Consequently, we believe is should be removed. As a substitute for this
       presentation format, you may consider presenting only individual non-GAAP
       measures (i.e., line items, subtotals, etc.) provided each one complies
       with Item 10 of Reg. S-K and the Division of Corporation Finance's
       Frequently Asked Questions Regarding Use of Non-GAAP Financial Measures,
       Question 8.

Response:         The Company acknowledges the Staff's comment with respect to
                  the Company's use of non-GAAP operating statement columnar
                  format. In light of this comment, the Company has considered
                  and revised this presentation format in a manner that the
                  Company believes addresses the Staff's concern. As described
                  above, the Company implemented this revised practice in
                  connection with the July Form 6-K.

                                      * * *
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                                                                      WilmerHale
Securities and Exchange Commission
July 26, 2006
Page 3

Please do not hesitate to contact the undersigned (212-937-7276) or Mr. Kropp
(617-526-6421) with any questions regarding this response letter.

Sincerely,

/s/ Robert A. Schwed

Robert A. Schwed

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                                  Exhibit A
                                  ---------

          AMDOCS LIMITED REPORTS 23% GROWTH IN REVENUE TO A RECORD $626
                  MILLION FOR THE THIRD QUARTER OF FISCAL 2006

           32% GROWTH IN DILUTED NON-GAAP EARNINGS PER SHARE TO $0.49;
                    DILUTED GAAP EARNINGS PER SHARE OF $0.39

Key highlights:

     -    Third quarter revenue grew 23% to $626 million

     -    32% increase in third quarter diluted non-GAAP EPS, excluding
          acquisition-related costs and equity-based compensation expense, net
          of related tax effects, to $0.49; Exceeds guidance of $0.46

     -    Diluted GAAP EPS of $0.39

     -    Free cash flow of $94 million for the quarter

     -    Qpass acquisition positions Amdocs as the leader in the emerging
          digital content market

     -    After the quarter, Amdocs announced that it signed an agreement to
          acquire Cramer Systems Group Ltd., a leading provider of operations
          support systems (OSS) software and solutions, for approximately $375
          million in cash, net of cash on hand

     -    Fourth quarter fiscal 2006 guidance: Expected revenue of approximately
          $657 million and diluted non-GAAP EPS of $0.49, excluding
          acquisition-related costs and approximately $0.04-$0.05 per share of
          equity-based compensation expense, net of related tax effects. Diluted
          GAAP EPS is expected to be approximately $0.41-$0.42. This guidance
          excludes any potential impact of the pending acquisition of Cramer

     -    Preliminary fiscal 2007 guidance: Expected revenue of approximately
          $2.880 - $2.980 billion and diluted non-GAAP EPS of $2.06 - $2.16,
          which exclude acquisition-related costs and approximately $0.19-$0.22
          per share of equity-based compensation expense, net of related tax
          effects. This guidance includes the expected impact of the pending
          acquisition of Cramer. Amdocs expects to provide guidance for 2007
          diluted GAAP EPS after the purchase price accounting for the
          acquisition is completed

ST. LOUIS, MO - JULY 19, 2006 - Amdocs Limited (NYSE: DOX) today reported that
for the quarter ended June 30, 2006, revenue was $626.4 million, an increase of
23.5% from last year's third quarter. Excluding acquisition-related costs, which
include amortization of purchased intangible assets and the write-off of
in-process research and development and

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excluding equity-based compensation expense, net of related tax effects, of
$20.6 million, net income on a non-GAAP basis was $106.2 million, or $0.49 per
diluted share, compared to non-GAAP net income, excluding $1.7 million of
acquisition-related costs net of related tax effects, of $78.8 million, or $0.37
per diluted share, in the third quarter of fiscal 2005. The Company's net income
was $85.6 million, or $0.39 per diluted share, compared to net income of $77.1
million, or $0.36 per diluted share, in the third quarter of fiscal 2005. Free
cash flow, defined as cash flow from operations less net capital expenditures
and principal payments on capital leases, was $94 million in the quarter.

"We are pleased to again report record revenues and increasing profitability,"
said Dov Baharav, chief executive officer of Amdocs Management Limited. "We see
demand in the market, which continues to be driven by service providers' need to
address competition, consolidation and convergence. We have strengthened our
presence in the digital content area with our acquisition of Qpass and we are
expanding our OSS activities with our pending acquisition of Cramer. Amdocs is
positioned as the only vendor that can provide an end-to-end solution, from
business support systems -- or BSS -- to OSS, for the leading services
providers. This will put us in the leading position to benefit from the growth
opportunities as service providers transform their organizations in order to
offer new products and services. We are confident that our success in 2006 will
continue as we look towards fiscal 2007."

During the third quarter, Amdocs new business included 11 key wins, across
geographies and lines of business. Amdocs expanded its relationship with Rogers
Communications, which will install Amdocs CRM across its cable, wireless and
telecom lines of business as part of a rollout of an integrated customer
management strategy. In Australia, Telstra has selected Amdocs as one of the key
vendors for an OSS transformational program. In the United States, Amdocs was
awarded several projects related to assisting customers in their consolidation
and integration of acquisitions. In broadband cable and satellite, a customer
has signed a contract extension. Several other customers, including some new
logos, have chosen Amdocs for CRM, Amdocs Partner Management and mediation
projects.

FINANCIAL OUTLOOK

Amdocs expects that revenue for the fourth quarter of fiscal 2006 will be
approximately $657 million. Diluted earnings per share on a non-GAAP basis for
the fourth quarter are

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expected to be $0.49, excluding acquisition-related costs and the impact of
approximately $0.04-$0.05 per share of equity-based compensation expense, net of
related tax effects. Diluted GAAP EPS is expected to be approximately
$0.41-$0.42. This guidance excludes any potential impact of the pending
acquisition of Cramer. Amdocs expects that it may incur a one-time charge in its
fourth fiscal quarter to account for certain costs related to the Cramer
acquisition.

Preliminary fiscal 2007 guidance: Expected revenue of approximately
$2.880-$2.980 billion and diluted non-GAAP EPS of $2.06-$2.16, which excludes
acquisition-related costs and approximately $0.19-$0.22 per share of
equity-based compensation expense, net of related tax effects. This guidance
includes the expected impact of the pending acquisition of Cramer. Amdocs
expects to provide guidance for diluted GAAP EPS after the purchase price
accounting for the acquisition is completed.

Amdocs will host a conference call on July 19, 2006 at 5 p.m. Eastern Time to
discuss the Company's third quarter results. The call will be carried live on
the Internet via www.InvestorCalendar.com and the Amdocs website,
www.amdocs.com.

NON-GAAP FINANCIAL MEASURES

This release includes non-GAAP diluted earnings per share and other non-GAAP
line items from the Non-GAAP Consolidated Statements of Income, including
non-GAAP cost of service, non-GAAP research and development, non-GAAP selling,
general and administrative, non-GAAP operating income, non-GAAP income before
income taxes, non-GAAP income taxes and non-GAAP net income. These non-GAAP
measures exclude the following items:

     -    amortization of purchased intangible assets;

     -    In-process research and development write-off;

     -    equity-based compensation expense; and

     -    tax effects related to the above.

These non-GAAP financial measures are not in accordance with, or an alternative
for, generally accepted accounting principles and may be different from non-GAAP
financial measures used by other companies. In addition, these non-GAAP
financial measures and the Non-GAAP Consolidated Statements of Income are not
based on any comprehensive

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set of accounting rules or principles. Amdocs believes that non-GAAP financial
measures have limitations in that they do not reflect all of the amounts
associated with Amdocs' results of operations as determined in accordance with
GAAP and that these measures should only be used to evaluate Amdocs' results of
operations in conjunction with the corresponding GAAP measures.

Amdocs believes that the presentation of non-GAAP diluted earnings per share and
other non-GAAP line items from the Non-GAAP Consolidated Statements of Income,
including non-GAAP cost of service, non-GAAP research and development, non-GAAP
selling, general and administrative, non-GAAP operating income, non-GAAP income
before income taxes, non-GAAP income taxes and non-GAAP net income, when shown
in conjunction with the corresponding GAAP measures, provides useful information
to investors and management regarding financial and business trends relating to
its financial condition and results of operations.

For its internal budgeting process and in monitoring the results of the
business, Amdocs' management uses financial statements that do not include
amortization of purchased intangible assets, in-process research and development
write-off, equity-based compensation expense, and related tax effects. Amdocs'
management also uses the foregoing non-GAAP financial measures, in addition to
the corresponding GAAP measures, in reviewing the financial results of Amdocs.
In addition, Amdocs believes that significant groups of investors exclude these
non-cash expenses in reviewing its results and those of its competitors, because
the amounts of the expenses between companies can vary greatly depending on the
assumpti