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SEC Company Response from AMDOCS LTD (DOX) (CIK 0001062579) (DOX) — Mar 22, 2011

AMDOCS LTD (DOX) (CIK 0001062579)
Date: March 22, 2011 · CIK: 0001062579 · Accession: 0000950123-11-027679

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File numbers found in text: 001-14840

Referenced dates: January 26, 2011

Date
March 22, 2011
Author
/s/ Thomas G. O’Brien
Form
CORRESP
Company
AMDOCS LTD (DOX) (CIK 0001062579)

Letter

March 22, 2011

By EDGAR Submission

Securities and Exchange Commission

Division of Corporation Finance

100 F Street, NE

Mail Stop 4561

Washington, DC 20549

Attention: Jaime John

Re:

Amdocs Limited

Form 20-F for the Fiscal Year Ended September 30, 2010

Filed December 7, 2010

File No. 001-14840

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 U.S. Securities and Exchange Commission (the “Commission”) in the letter dated January 26, 2011 from Patrick Gilmore, Accounting Branch Chief, of the U.S. Securities and Exchange Commission (the “Commission”), to Thomas G. O’Brien, Treasurer and Secretary of Amdocs.

In the comment letter, the Staff requested that the Company acknowledge certain matters with respect to the 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 filing to be certain that the filing includes the information the Securities Exchange Act of 1934 and applicable Exchange Act rules require. 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 provide a written 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

U.S. Securities and Exchange Commission

March 22, 2011

Page 2

•

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.

By this letter, the Company hereby acknowledges 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.

* * * * *

U.S. Securities and Exchange Commission

March 22, 2011

Page 3

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

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CORRESP
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corresp

March 22, 2011

By EDGAR Submission

Securities and Exchange Commission

Division of Corporation Finance

100 F Street, NE

Mail Stop 4561

Washington, DC 20549

Attention: Jaime John

    Re:

     Amdocs Limited

Form 20-F for the Fiscal Year Ended September 30, 2010

Filed December 7, 2010

File No. 001-14840

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 U.S. Securities and Exchange Commission (the
“Commission”) in the letter dated January 26, 2011 from Patrick Gilmore, Accounting Branch Chief,
of the U.S. Securities and Exchange Commission (the “Commission”), to Thomas G. O’Brien, Treasurer
and Secretary of Amdocs.

     In the comment letter, the Staff requested that the Company acknowledge certain matters with
respect to the 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 filing to be certain that the filing includes the information the Securities Exchange
Act of 1934 and applicable Exchange Act rules require. 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 provide a written 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

U.S. Securities and Exchange Commission

March 22, 2011

Page 2

    •

    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.

     By this letter, the Company hereby acknowledges 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.

* * * * *

U.S. Securities and Exchange Commission

March 22, 2011

Page 3

     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